On 19 February 2021 Cyprus and Germany signed an amending protocol to their existing Double Tax Treaty (DTT) of 2011.
The 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 and other amendments that have been bilaterally agreed upon.
Since the DTT between the two countries has not been covered by the Multilateral Convention, the aim of which is to introduce automatically and expedite BEPS Actions, the main amendments in the protocol include the incorporation of specific wording in the Preamble and the amendment of the relevant entitlement to benefits article. In addition, specific wording was introduced in the article on business profits.
