The protocol amending the double tax convention between the Republic of Cyprus and the Swiss Confederation which was signed on 20 July 2020 in Nicosia, Cyprus came into effect on 3 November 2021 (please see Circular 3/2022). The protocol relates to the avoidance of double taxation in respect of taxes on income and on capital.
The protocol introduces, among other things, the mandatory minimum standards of the Organisation for Economic Cooperation and Development’s (OECD’s) Base Erosion and Profit Shifting (BEPS) actions regarding arrangements on bilateral conventions and verbal amendments agreed bilaterally. The agreement is based on the OECD Model Convention for the Avoidance of Double Taxation on Income and on Capital. The amendments made to the DTT focus on business profits, associated enterprises, mutual agreement procedures and benefit entitlement.
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.