Protocol to Double Tax Treaty between Cyprus and Switzerland

On 20 July 2020, an amending Protocol to the existing Double Tax Treaty (DTT) of 2014 was signed between the Republic of Cyprus and the Swiss Confederation.

As the DTT has not been covered by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (known as Multilateral Instrument), the Protocol introduces, among others, the minimum standards of the OECD Base Erosion and Profit Shifting (BEPS) project, related to bilateral agreements and other amendments that have been bilaterally agreed upon.

The main amendments introduced by the Protocol include the incorporation of specific wording in the Preamble of the treaty and the introduction of the ‘Entitlement to Benefits’ article. In addition, specific wording was introduced in the ‘Mutual Agreement Procedure’ article. 

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