The first Double Tax Treaty (DTT) between Cyprus and Luxembourg signed on 8 May 2017 is effective as from 1st of January 2019 based on a recent update of the Cyprus Ministry of Finance.
The DTT provides:
0% withholding tax (WHT) rate on interest and royalties.
0% WHT rate on dividends applies for corporate investors holding directly at least 10% of the capital of the paying company; a 5% WHT rate applies in all other cases of dividends.