Switzerland and Cyprus have signed a protocol amending their agreement for the avoidance of double taxation with respect to taxes on income and capital (DTA). This protocol implements the minimum standards for double taxation agreements from the BEPS project.
It contains an anti-abuse clause which refers to the main purpose of an arrangement or transaction and thus ensures that the DTA is not abused.
The amendment will have to be approved by the legislators in both countries before it can come into force.