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.
For more information please speak with our dedicated Tax Planning and Advanced Business Structuring team or with your usual contact at Elias Neocleous & Co LLC.