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A protocol amending the current double tax convention between the Republic of Cyprus and the Federal Republic of Germany was signed on 19 February 2021 in Nicosia, Cyprus.
A protocol amending the current double tax convention between
the Republic of Cyprus and the Federal Republic of Germany was
signed on 19 February 2021 in Nicosia, Cyprus. The protocol relates
to the avoidance of double taxation in respect of taxes on income
and on capital.
The double tax convention with the German Federation is not
covered by the Multilateral Convention, meaning that the Base
Erosion and Profit Shifting (BEPS) actions were not automatically
included in the original convention. Therefore, the purpose
of the signed protocol is to introduce, amongst other things, the
minimum standards of the BEPS actions of the Organization for
Economic Co-operation and Development relating to bilateral
agreements and, other amendments that have been bilaterally agreed
upon.
The main changes to the convention include the incorporation of
specific wording in the preamble, amendments to the entitlement to
benefit article and, the insertion of specific wording under
business profits.
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.