Protocol between the Government of the Republic of Cyprus and the Swiss Federal Council
The Protocol for the Avoidance of Double Taxation with respect to Taxes on Income and on Capital was signed today July 20th 2020 in Nicosia between the Government of the Republic of Cyprus and the Swiss Confederation. On behalf of the Republic of Cyprus the protocol was signed by Mr. Constantinos Petrides, Minister of Finance, and on behalf of the Swiss Confederation, the Protocol was signed by the Ambassador of Switzerland to Cyprus Honorable Dr. Pierre-Yves Fux.
The signed Protocol introduces, among others, the minimum standards of the Base Erosion and Profit Shifting (BEPS) actions of the Organization for Economic Co-operation and Development, related to bilateral agreements and other amendments that have been bilaterally agreed upon.
Since the Double Taxation Convention with the Swiss Federation has not been covered by the Multilateral Convention, the aim of which was to introduce automatically and speedily BEPS Actions, the main amendments in the protocol include the incorporation of specific wording in the Preamble of the Convention and the introduction of the ‘Entitlement to Benefits’’ Article. In addition, specific wording was introduced in the ‘Mutual Agreement Procedure’ Article.
Upgrading and expanding the network of Double Taxation Conventions is of high economic and political importance and aims to further strengthening and attracting investments by promoting Cyprus as an international business centre.
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