13 February 2020

Cyprus Tax Authorities publish 10-year government bond yield rates for NID purposes

Executive summary

On 12 February 2020, the Cypriot Tax Department (CTD) announced the 10-year government bond yield rates as at 31 December 2019 for a number of countries (set forth in the table below) with respect to the Notional Interest Deduction (NID) on equity. These yield rates are to be used to determine the reference interest rate for claiming NID in respect of the 2020 tax year.

The key NID provisions and the applicability of the 10-year government bond yield rates are summarized below.

Detailed discussion

Notional Interest Deduction

As of 1 January 2015, Cyprus tax resident companies (as well as foreign companies with permanent establishments in Cyprus), which carry on a business, are entitled to claim a NID on their equity capital introduced on or after 1 January 2015.

The NID is deducted from the taxable income of the company for the relevant tax year (subject to any restrictions) for the period of time within the tax year during which the equity belongs to the company and is used by that company for the carrying on of its activities.

The NID will equal the multiple of the “reference interest rate” (as defined below) and ‘’new equity.’’

“Reference interest rate” means the yield rate (not the coupon rate) as at 31 December of the year preceding the tax year of the 10-year government bond of the country in which the new capital is invested increased by 3%. However, the reference interest rate cannot be lower than the yield rate of the 10-year government bond of Cyprus increased by 3%.

10-year government bond yield rates as at 31 December 2019 (applicable for 2020 tax year)

Country
Yield rate
Country
Yield rate

Abu Dhabi

2,514

Kazakhstan (US$)

2.566

Argentina

10,253

Kenya

12.180

Armenia

8,064

Latvia

0.136

Austria

0.016

Lithuania

0.169

Belarus (US$)

5.350

Luxembourg

-0.087

Belgium

0.086

Morocco

2.420

British Virgin Islands

N/A*

Mauritius

4.260

Bulgaria

0.257

Netherlands

-0.060

Canada

1.699

Nigeria

11.563

Cayman Islands

N/A*

Nigeria (€)

N/A*

China

3.130

Norway

1.540

Croatia

0.621

Poland

2.109

Cyprus

0.536

Romania

4.398

Czech Republic

1.569

Russia

6.270

Dubai (€)

N/A*

Russia (US$)

2.605

Dubai (US$)

3.160

Saudi Arabia

2.839

Egypt

13.518

Serbia

2.778

Egypt (US$)

6.382

Singapore

1.730

Finland

0.043

Slovakia

0.192

France

0.115

Slovenia

0.267

Germany

-0.210

South Africa

9.018

Greece

1.431

Spain

0.463

Hong Kong

1.699

Sweden

0.145

Hungary

2.017

Switzerland

-0.454

India

6.557

Taiwan

0.670

Ireland

0.120

United States

1.919

Isle of Man

1.712

Ukraine (€)

N/A*

Israel

0.960

Ukraine (US$)

6.504

Israel (US$)

2.520

United Arab Emirates

N/A*

Italy

1.404

United Kingdom

0.817

Ivory Coast

N/A*

Vietnam

3.459

Kazakhstan (€)

0.996

  

* There are currently no government bond yield rates for the above indicated countries.

For additional information with respect to this Alert, please contact the following:

Ernst & Young Cyprus Limited, International Tax and Transaction Services, Nicosia

ATTACHMENT

Document ID: 2020-5220