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Note: This Treaty may be impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (MLI). MLI impact on Tax Treaties is available with the Orbitax International Tax Research & Compliance Expert.

ARTICLE 22

Elimination of Double Taxation

(1) In the case of Cyprus, double taxation shall be avoided as follows:

  • Subject to the provisions of Cyprus tax law regarding credit for foreign tax, there shall be allowed as a credit against Cyprus tax payable in respect of any item of income derived from Andorra the tax paid under laws of Andorra and in accordance with this Convention. The credit shall not, however, exceed that part of Cyprus tax, as computed before the credit is given, which is appropriate to such items of income.

(2) In the case of Andorra, double taxation shall be avoided as follows:

  • (a) Where a resident of Andorra derives income which, in accordance with the provisions of this Convention, may be taxed in Cyprus, Andorra shall allow as a deduction from the tax on the income of that resident an amount equal to the tax paid in Cyprus. Such deduction shall not, however, exceed that part of the Andorran tax, as computed before the deduction is given, which is attributable to such items of income derived from Cyprus;
  • (b) Where a resident of Andorra derives income which, in accordance with the provisions of this Convention, is exempt from tax in Andorra, Andorra may in order to calculate the amount of tax on the remaining income of such resident, take into account the income that has been exempted.