DECLARATION AS A NOTIFIED JURISDICTIONAL AREA UNDER SECTION 94A OF THE INCOME TAX ACT, 1961 – CLARIFICATION PROVIDED BY MINISTRY OF FINANCE, GOVERNMENT OF CYPRUS. - Income Tax - PRESS RELEASE

The Ministry of Finance of the Republic of Cyprus wishes to state that: "The Ministry of Finance of the Republic of India has issued a press release on November 1st, 2013 stating that it has taken the decision to notify Cyprus as a notified jurisdictional area under section 94A of the Income-tax Act, 1961 . The Ministry of Finance of the Republic of India has taken the above unilateral measure, considering that in their view the information provided by the competent authorities of the Republic of Cyprus, under the existing double tax treaty between Cyprus and India did not adequately address the inquiries of the relevant authorities of the Republic of India. It is important to clarify that the double tax treaty between the two countries has not been terminated. Given the fact that Cyprus attaches primary importance to the implementation of its contractual obligations stemming from Bilateral and International Agreements, and paying due respect to the excellent level of its political relations with the Government of India, the Cypriot Government is in direct contact with the Indian Government and is exerting every effort to clarify and resolve the situation that has been created and has directly affected the business communities in both countries. It is the position of the Cypriot Government that any discrepancies and points that need clarification can only be resolved through direct consultations between the concerned competent authorities, which have been agreed to take place within November 2013. The Government of the Republic of Cyprus reiterates its commitment for holding direct negotiations with the Government of the Republic of India with the aim of finalising the long pending review of the double tax treaty between Cyprus and India."