Corporate Taxation

Cyprus and Switzerland sign protocol to amend the tax treaty

A new protocol was signed, amending the existing tax treaty between Cyprus and Switzerland (the treaty) on July 20 2020.

In the recent article by our member, Taxand Cyprus, the signed protocol introduces, among others, the minimum standards of the BEPS actions of the OECD, relating to bilateral agreements and other amendments that have been bilaterally agreed upon.

In compliance with BEPS Action 6, it is incorporated within the treaty a specific wording of the preamble, stating that the treaty “intends to eliminate double taxation with respect to the taxes covered by this agreement without creating opportunities for non-taxation through tax evasion or avoidance (including through treaty-shopping arrangements aimed at obtaining reliefs provided in this agreement for the indirect benefit of residents of third States)”.

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