Amending Protocol to Tax Treaty between Cyprus and Germany has Entered into Force

The amending protocol to the 2011 income and capital tax treaty between Cyprus and Germany entered into force on 8 December 2021. The protocol, signed 19 February 2021, is the first to amend the treaty and includes the following changes:

• The preamble is replaced in line with OECD BEPS standards;
• Article 7 (Business Profits) is replaced with updated provisions in line with OECD standards;
• Article 27 (Application of the Agreement in Special Cases) is amended with the addition of a second parag…