ARTICLE
7 February 2022

Protocol Amending The Double Tax Convention Between The Republic Of Cyprus And The Federal Republic Of Germany

EN
Elias Neocleous & Co LLC

Contributor

Elias Neocleous & Co LLC is the largest law firm in Cyprus and a leading firm in the South-East Mediterranean region, with a network of offices across Cyprus (Limassol, Nicosia, Paphos), Belgium (Brussels), Czech Republic (Prague), Romania (Budapest) and Ukraine (Kiev). A dynamic team of lawyers and legal experts deliver strategic legal solutions to clients operating in key industries across Europe, Asia, the Middle East, India, USA, South America, and China. The firm is renowned for its expertise and jurisdictional knowledge across a broad spectrum of practice areas, spanning all major transactional and market disciplines, while also managing the largest and most challenging cross-border assignments. It is a premier practice of choice for leading Cypriot banks and financial institutions, preeminent foreign commercial and development banks, multinational corporations, global technology firms, international law firms, private equity funds, credit agencies, and asset managers.
The protocol relates to the avoidance of double taxation in respect of taxes on income and on capital.
Cyprus Tax

The protocol amending the double tax convention between the Republic of Cyprus and the Federal Republic of Germany which was signed on 19 February 2021 in Nicosia, Cyprus came into effect on 8 December 2021 (please see Circular 2/2022). 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.

Mondaq uses cookies on this website. By using our website you agree to our use of cookies as set out in our Privacy Policy.

Learn More