18 February 2025 Cyprus Tax Authority publishes 10-year government bond yield rates for Notional Interest Deduction purposes - Cyprus has announced the 10-year government bond yield rates for various countries as of 31 December 2024, to be used for purposes of the Notional Interest Deduction (NID) on equity for the 2025 tax year.
- Cyprus tax-resident companies and foreign companies with permanent establishments in Cyprus can claim NID on new equity introduced on or after 1 January 2015.
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On 14 February 2025, the Cypriot Tax Department issued an announcement that lists the 10-year government bond yield rates as of 31 December 2024 for a number of countries (listed in the table below) with respect to the Notional Interest Deduction (NID) on equity. These yield rates should be used to determine the reference interest rate for claiming NID for the 2025 tax year. The key NID provisions and the applicability of the 10-year government bond yield rates are summarized below. Notional Interest Deduction As of 1 January 2015, Cyprus tax-resident companies (as well as foreign companies with permanent establishments in Cyprus) are entitled to claim a NID on their equity capital introduced on or after 1 January 2015 (referred to as "new equity"). The NID is deducted from the company's taxable income for the relevant tax year (subject to any restrictions) for the period of time during which the company used the equity in carrying on its activities. The NID is subject to a number of conditions, including a taxable-income limitation. The NID equals the multiple of the reference interest rate (as defined below) and new equity. "Reference interest rate" means the 10-year government bond yield of the country in which the new equity is invested, as of 31 December of the year preceding the tax year, increased by 5%. 10-year government bond yield rates1 as of 31 December 2024 (applicable for 2025 tax year)2 Country | Yield rate | Country | Yield rate | Abu Dhabi | 5.018 | Jordan (US$) | 7.355 | Albania | N/A* | Kazakhstan (€) | 3.726 | Albania (€) | 4.615 | Kazakhstan (US$) | 5.141 | Angola (US$) | 11.123 | Kenya | 10.739 | Argentina | 5.537 | Kuwait | N/A* | Armenia | 7.224 | Latvia | 3.423 | Australia | 4.437 | Lebanon | N/A* | Austria | 2.884 | Lithuania | 3.537 | Azerbaijan (US$) | 5.855 | Luxembourg | 2.899 | Bahrain (US$) | 6.835 | Malaysia | 3.877 | Belarus (US$) | 25.438 | Malta (€) | 3.951 | Belgium | 2.952 | Mauritius | 5.065 | Bermuda (US$) | 5.574 | Mexico | 10.030 | Bosnia and Herzegovina | N/A* | Mexico (€) | 4.644 | British Virgin Islands | N/A* | Mexico (US$) | 6.184 | Bulgaria | 3.440 | Moldova | N/A* | Brazil | 15.193 | Montenegro | 4.496 | Brazil (US$) | 6.799 | Morocco | 3.007 | Cameroon (€) | 9.579 | Netherlands | 2.596 | Canada | 4.324 | New Zealand | 4.452 | Cayman Islands | N/A* | Nigeria | 19.170 | Chile | 5.960 | Nigeria (€) | N/A* | Chile (€) | 3.788 | North Macedonia (Skopje) (€) | N/A* | Chile (US$) | 5.458 | Norway | 3.841 | China | 2.941 | Oman (US$) | 5.761 | Colombia | 11.182 | Pakistan | N/A* | Colombia (US$) | 7.559 | Pakistan (US$) | 11.418 | Costa Rica | 6.652 | Panama (US$) | 7.215 | Croatia | 3.129 | Poland | 3.361 | Cyprus | 2.980 | Portugal | 2.755 | Czech Republic | 4.087 | Qatar (US$) | 4.870 | Denmark | 2.179 | Romania | 7.332 | Dubai (€) | N/A* | Russia | 14.380 | Dubai (US$) | 4.520 | Russia (US$) | N/A* | Egypt | 26.008 | Saudi Arabia | 5.326 | Egypt (US$) | 9.820 | Serbia | 6.197 | Estonia | 3.420 | Singapore | 2.851 | Finland | 3.017 | Slovakia | 3.359 | France | 3.278 | Slovenia | 3.013 | Georgia | 7.690 | South Africa | 9.940 | Germany | 2.500 | Spain | 3.013 | Guernsey | N/A* | Sweden | 2.411 | Ghana | 33.896 | Switzerland | 0.269 | Ghana (US$) | 9.937 | Taiwan | 1.633 | Greece | 3.898 | Tunisia | N/A* | Hong Kong | 2.601 | Turkiye | 27.190 | Hungary | 6.519 | Turkiye (€) | 4.794 | India | 7.027 | Turkiye (US$) | 7.365 | Indonesia | 6.773 | United States | 4.572 | Indonesia (US$) | 4.865 | Ukraine | N/A* | Indonesia (€) | 3.887 | Ukraine (€) | N/A* | Iraq | N/A* | Ukraine (US$) | 13.426 | Ireland | 2.898 | United Arab Emirates | N/A* | Isle of Man | 5.387 | United Kingdom | 4.565 | Israel | 4.827 | Uruguay | 3.202 | Israel (US$) | 6.166 | Uruguay (US$) | 5.370 | Italy | 4.002 | Uzbekistan (US$) | 7.304 | Ivory Coast | 7.891 | Vietnam | 2.580 | Jamaica | 8.060 | | | Japan | 1.037 | | |
* There are currently no government bond yield rates for the above indicated countries. * * * * * * * * * * | Endnotes1 The 10-year government bond yield rate of each country is in local currency unless otherwise denoted in the table. 2 The Cypriot Tax Department may update the list during the year. As such, it is advisable to check their website for any changes or new additions to the list. Please visit: Tax Department | Announcements (mof.gov.cy). | * * * * * * * * * * | Contact Information | For additional information concerning this Alert, please contact: EY Cyprus Advisory Services Limited, International Tax and Transaction Services, Nicosia Ernst & Young LLP (United States), BEPS Tax Desk, New York | Published by NTD’s Tax Technical Knowledge Services group; Carolyn Wright, legal editor |
Document ID: 2025-0513 |