Cyprus and Germany have signed a new Agreement on the Avoidance
of Double Taxation, which, when ratified, will replace the existing
agreement of 1974 ("the 1974 agreement").
Most of the changes brought about by the new agreement merely
reflect changes to the OECD Model Tax Convention (for example,
there is no longer an article covering personal services) or
updating of definitions (for example, the 1974 agreement referred
only to income tax in Cyprus, whereas the new agreement specifies
all the taxes covered). However, a number are more substantial.
Permanent establishment
Article 5(3) of the new agreement extends the definition of a
construction or installation project to include supervisory
activities, but no permanent establishment arises until after 12
months' activity. (Under the 1974 agreement a permanent
establishment arose after six months).
Article 5(5) provides that the exercise of activities on behalf
of a
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The Cyprus International Trust (Video)
