The French General Directorate of Public Finance has published the synthesized text of the 1981 income and capital tax treaty with Cyprus as impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The text is intended to facilitate the reading of the treaty as impacted by the MLI based on the reservation and notifications deposited by France and Cyprus. The text is not a substitute for the respective authentic texts of the treaty and the MLI, which remain the only applicable legal instruments.

As provided in the synthesized text, the MLI applies for the 1981 France-Cyprus tax treaty:

• with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2021; and
• with respect to all other taxes levied by a Contracting State, for taxes levied with respect to taxable periods beginning on or after 1 November 2020.

Click the following link for the tax treaty page of the General Directorate of Public Finance, which includes the MLI synthesized texts.