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

15 November 2021

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Treaty Development

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Cyprus-Switzerland

The amending protocol to the 2014 income and capital tax treaty between Cyprus and Switzerland entered into force on 3 November 2021. The protocol, signed 20 July 2020, is the first to amend the treaty and includes the following changes: The preamble is replaced in line with BEPS standards; Article 7 (Business Profits) is amended with the addition of a new paragraph 4 providing that a Contracting State shall make no adjustment to the profits that are attributable to a permanent establishment of an enterprise of one of the Contracting States after 6 years from the end of the taxable...