The existing tax treaty between Cyprus and Germany has been amended
On February 19 2021, a new protocol was signed (protocol), amending the existing tax treaty between Cyprus and Germany (the treaty). Following a decision of the Minister of the Council dated October 23 2019, the signed protocol was published in the Official Gazette of Cyprus in accordance with the provisions of Article 169.3 of the Cyprus Constitution.
Changes to the tax treaty
The new protocol introduces, among others, the OECD BEPS minimum standards dealing with treaty shopping and other amendments that have been bilaterally agreed upon
Incorporation of the preamble
As part of the BEPS package, Action 6 sets out one of the four BEPS minimum standards, dealing with treaty shopping. Specifically, according to the OECD BEPS project, it requires jurisdictions to include two components in their tax agreements: an express statement on non-taxation (generally in the preamble) and one of three methods of addressing tr