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

20 December 2021

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Treaty Development

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Cyprus-Germany

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 paragraph providing that a benefit under the treaty will not be granted in respect of an item of income...