Cyprus And Switzerland Signed Protocol Amending The Double Taxation Treaty


Cyprus and Switzerland signed on Monday a protocol amending the Treaty for the avoidance of double taxation, with the two sides stating that the amended treaty will boost their economic ties.
The Protocol signed by the Minister of Finance Constantinos Petrides on behalf of Cyprus and Ambassador Pierre-Yves Fux on behalf of Switzerland, introduces, among others, the minimum standards of the OECD’s bare erosion and profit shifting as well as provisions concerning the benefit entitlement.

Speaking to the press after the signing ceremony, Petrides said “the signing of this protocol emphasises the very good relations in the economic and political sphere between the two jurisdictions,” adding that he looks forwards for further advancing and strengthening a mutual beneficial relationship between Cyprus and Switzerland.

“The Republic of Cyprus is confident that an environment that provides certainty also in tax matters is conducive for the promotions of investments, growth and job creation,” he added.

On his part, Pierre-Yves Fux described the signing of the protocol as “a little, but important milestone in our relations,” noting that “this treaty is a tool to strengthen the framework for our financial and economic relations and also a tool to create worldwide a safer environment with regard to financial and other transactions.”

“I hope that we will a very good framework for our trade and commercial relations thanks to such a protocol and we will continue and develop our very good and bilateral relations on all levels, political, tourism, culture etc., and of course the financial aspect,” he said.
Negotiations on treaty change with Russia to conclude in the coming weeks

Furthermore, asked on the negotiations with the Russian Federation concerning a request by Moscow to amend the Double Taxation Treaty with Cyprus, Petrides said he expects negotiations to conclude in the coming weeks.

Russia requested a renegotiation of the Double Tax Treaty (DTT) agreement between the two countries, asking for the increase in the withholding on tax rates on dividend income from 5% or 10% (subject to conditions) to 15%, and on interest income from 0% to 15%.

“We are in constant communication with the Russian authorities and negotiation are in progress,” Petrides said, adding that “from the outset we have stated our will to find a mutually agreed solution to the matter.”

He added that in the context of the negotiations Cyprus has requested “some exemptions and other issues.”

Petrides also stressed that “for us it is very important the position stated by the Russian side that the treaty will not only concern Cyprus but also other jurisdictions must be implemented.”