Cyprus Tax Alert September 2009Cyprus-Germany Protocol to Tax Treaty |
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Cyprus and Germany initialed a new Protocol to their 1974 Tax Treaty. The Protocol replaces the existing Treaty's Article 26 on Exchange of Information. The new Article 26 adopts the wording of the 2008 OECD Model Convention with one extension of scope. This extension allows for a Contracting State to use information received for non-tax purposes but only where the domestic laws of both Cyprus and Germany allow for this other use and also that the supplying State authorizes such use by the State that receives it.
The Protocol also provides for a comprehensive list of information to be provided by a Contracting State when making a request which follows Cyprus's domestic law requirements for providing information and includes provisions for the protection of personal data.
The Protocol is expected to come into force immediately upon ratification by both the Cypriot and German Parliaments.