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

The amending protocol to the 2014 income and capital tax treaty between Cyprus and Switzerland entered into force on 3 November 2021. The protocol, signed 20 July 2020, is the first to amend the treaty and includes the following changes:

• The preamble is replaced in line with BEPS standards;
• Article 7 (Business Profits) is amended with the addition of a new paragraph 4 providing that a Contracting State shall make no adjustment to the profits that are attributable to a permanent establishment…