Protocol amending the Cyprus Germany Tax Treaty

On 19 February 2021, Cyprus and Germany signed a Protocol amending the existing Cyprus Germany Tax Treaty.

On behalf of the Republic of Cyprus, the protocol was signed by the Minister of Finance, Mr. Constantinos Petrides, and on behalf of the Federal Republic of Germany, by the Ambassador of Germany to Cyprus Mr. Franz Josef Kremp.

The signed Protocol introduces, among others, the minimum standards of the BEPS Project (Base Erosion and Profit Shifting) actions of the OECD, related to bilateral agreements and other amendments that have been bilaterally agreed upon.

Since the existing Tax Treaty with Germany has not been covered by the Multilateral Convention, the aim of which was to introduce automatically and expedite BEPS Actions, the main amendments in the protocol include the incorporation of specific wording in the Preamble of the Convention and the amendment of the relevant entitlement to benefits article ‘Application of the Agreement in Special Cases’ Article. In addition, specific wording was introduced in the ‘Business profits’ Article.

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We are at your disposal to discuss the effect of the above provisions to your corporate structure and arragements.

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