Cyprus: Protocols with Germany and Switzerland in effect

Protocols have an effective date of 1 January 2022

Protocols have an effective date of 1 January 2022

Ratification of Protocols amending the income tax treaties between Cyprus and Germany and between Cyprus and Switzerland has been completed, and the agreements have entered into force.

Protocol with Germany

The Cyprus tax authority on 2 February 2022 issued a circular (Circular 2/2022) stating that the legal procedures for the entry into force of a Protocol to the Cyprus-Germany income tax treaty have been completed in both jurisdictions.  

The German Protocol entered into force on 8 December 2021 and has an effective date of 1 January 2022.

The main changes that the Protocol makes to the Cyprus-Germany income tax treaty (2011) are the introduction of the BEPS minimum standards and amendments to Article 7 “Business Profits” in line with the OECD Model Tax Convention (2017).

Read a February 2022 report prepared by the KPMG member firm in Cyprus

Protocol with Switzerland

The Cyprus tax authority on 3 February 2022 issued a circular (Circular 3/2022) stating that the legal procedures for the entry into force of a Protocol to the Cyprus-Switzerland income tax treaty have been completed in both jurisdictions.  

The Swiss Protocol entered into force on 3 November 2021 with certain provisions having effect on the same day and the remaining having an effective date of 1 January 2022.

The main amendments that the Protocol makes to the Cyprus-Switzerland income tax treaty (2014) are the introduction of the BEPS minimum standards with an effective date of 1 January 2022 and amendments to Article 7 “Business Profits” and Article 9 “Associated Enterprises” with an effective date of 3 November 2021.

Read a February 2022 report prepared by the KPMG member firm in Cyprus

 

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