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434
ΕΠΙΣΗΜΗ ΕΦΗΜΕΡΙΔΑ ΤΗΣ 4ης ΑΠΡΙΛΙΟΥ
1984
Artic1e 12
DIVIDENDS
(1)
Dividends derived from sources within Cyprus by a
resident of the United States shall not be subject to
&n3
tax imlIosed by Cyprus in excess of the tax imposed wi th
respect to the protits or earnings out of whioh such
dividends are pa1d.
An
indiv1dual resident
ο!
tbe United
States shall be entitled to a refund of any Cypriot tax
im~osed
with respect to the profits or earnings out
ο!
whioh
a dividend 18 paid to the extent that said tax exceeds the
individual's tax liability
ίη
Cyprus.
(2) The rate
ο!
tax imposed by the United States on
dividends, other than dividends
ο!
the type desoribed
ίη
paragraph 4(b), derived from sources within tbe United
States by a resident
ο!
Cyprus sha11 not exceed:
(a)
15
pe1"cent
ο!
the gross amou.nt
ο!
the dividend; or
(b) When the recipient is a oorporation,
5
percent
ο!
the gross amount
ο!
the dividend 1f:
(i)During tr.e part
ο!
the paying corporation's
taxable year which precedes the date
ο!
payment
ο!
the div1dend and during the who1e
ο!
its
prior taxab1e year (if
8.l13),
at least 10 perce.nt
ο!
the outstanding shares
ο!
the
votiΔg
stock
ο!
the paying corporation was owned by the
reoipient corporation; and
(i1) Not more than 25 percent
ο!
tte gross income
ο!
the
pByίΔg
corporation for suoh prior taxable
year
(if
any)
cons1sts
ο!
interest or ' div1dends
(other. tt.an il1terest derived
trom
the conduct
ot
banking,
iΔsurance,
or t1nancing bus1ness and
dividends or interest I'eceived from subsidiary
corporations, 50 percent or more of the
outstandi~
shares of the voting stock
ο!
which is owned
by
the
paying corporation at the time such
divideΔdsοr
interest is
receivεd).
(3)
Paragraphs (1) and (2) shall not apply
if
the recipient
ο!
the dividends, being a resident
ο!
a Contracting State,
has in the other
Cοntrεcting
State a per.manent establishment
and the shares with respect to which the dividends are pa1d