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ΕΠΙΣΗΜΟΣ ΕΦΗΜΕΡΙΣ
ΤΗΣ ΚΥΠΡΙΑΙ<ΗΣ ΔΗΜΟΚΡΑΤΙΑΣ
'Αριθμός
1788
Ι
Παρασκευή
9
'Ιοuλίοu
1982
659
"Αριθμός
1468
CONVENTION
between
the Government of the F'rench
Republιic
and
the Government
οί
the Republic of Cypru's
for the avoidance of double taxation and
the prevention of fisca1 evasion with respect
to taxes
οη
income and
οη
capital.
The Govemment of the French Republic
and
The Government
οί
the Republic of Cyprus
desiήng ιο
conclude a Convention for the avoidance
οί
double taxation and ,the prevention of fiscaI
evasion with respect
Ιο
taxes
οη
income and
οη
capital,
have agreed as follows:
AJRTICLE 1
PERSONA!L SCOPE
This
Conventιionshall
apply
Ιο
persons who
are residents
οί
one or both
οί
the Sta,tes.
ARTICLE
2
TAXES COVERBD
1. This Convention shaH apply
Ιο
taxes
οη
income and
οη
capital imposed
οη
beha:lf
οί
a
State or,
ίη
the case of FI"anCe,
οη
behalf of its
territor;ial
authοήtίes
and,
ίη
the case of Cyprus,
οη
behalf
οί
its p01i<tical
su,bdίvisions
of local
authorities,
irrespectίve οί
the manner
ίη
which
tJhey are
leVΊed.
ι
2. ThereshaJl be rega:rded as 'taxes
οη
income
and
οη
capital taxes imposed
ση
total inoome,
οη
total capi,tal, or
οη
elements of income
ΟΓ
of capital,
includίng
taxes
οη
gains from the
alienation of movable
ΟΓ
immovable property,
taxes
οη
the total amounts of wages
οτ
salaries
paid by enterprises, as well
aιs
taxes
οη
capital
appreciation.
3. The existing taxes
Ιο
w,hich the Convention
shall apply are:
(a)
ίη
the case
οί
France:
ο)
the income
rtax;
(ίί)
the corporation tax;
including any with'holding tax, pre–
payment (precompte) or advance
payment wjth res'pect
Ιο
the aforesaid
taxes;
(hereinafter refer'red
Ιο
as "French
tax");
(b)
inthe case
οί
Cy:prus:
~ϊ)
the Income tax
(hereinafter referred
Ιο
as "Cyprus
tax").
4.
The Convention shall apply
ώso Ιο
any
identical or substantiaIly s·imila;r taxes which are
imposed after the date of signatu're
οί
the Con–
vention
ίη
addition to,
ΟΓ ίη
place
οί,
the
existing taxes. The
comρetent
authorities of the
States shall Dotify each other of substantial
changes which have been made
,ίη
,thei'r respe–
ctive taxation laws.
AJRTICLE
3
GENERAL DEFINITIONS
,
1. For the purp05e6 of this
Cοηνentiοn,
unless
the context otherwise reqU'ires-
(a) the terms "a
State"
and "the other
State" mean France
ΟΓ
Cyprus as the
case may be;
(b)
~he
term "person" includes an
ίndivi
dual, a company and any other body of
persons;
(c) the term "company" means any body
corporarte or any enti,ty which ,i,s treated
as a
bod
Υ
corporate for
ιtax
purposes;
(d) the term's "enterprise of a State" and
" 'enterprise of the other
Staιte"
mean
respectively an enterprise carried
οη
by
a resident of a State and an
eπterpήse
carried
0'0
by a resident of the other
State;
(e) the term "international traffic" means
any transport by a sh'ip
στ
a·ircraft ope–
ra:ted by an enterprise w,hich has its
place of effecHve
ffi'aηagemeηt ίη
a
State. except when the
shίp
or aircraft
is opera:ted solely between places
ίη
the
other State;
([) t:he term "competent authority" means:
(ί) ίη
the case of France, the
Minίster
,ίη
charge
οί
the Budget or his autho–
rized representative;