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Posts Tagged ‘BEPS’

Transfer Pricing - Assessment Method for Financing Transactions

Through a circular issued on 7 July 2023, the Cyprus Tax Department (TD) clarified the method it considers as the most appropriate for determining the arm’s length pricing for financing transactions, including those of a “back-to-back” nature.

Transfer Pricing Circular for Transactions Under the Local File Threshold

The Cyprus Tax Department issued a circular for transactions falling below the threshold for the preparation of a Local File.

Reference Interest Rates for Notional Interest Deduction on Equity

The Cyprus Tax Department issued an announcement on 23 May 2023 concerning the 10-year government bond yield rates as at 31 December 2020, 2021 and 2022 for a number of countries.

ATAD 3: EU Unshell Directive

The Directive targets EU tax resident entities that are engaged in cross-border economic activities but have little or no economic substance, known as “shell entities”.

Reference Interest Rates for 2023 for Notional Interest Deduction on Equity

The Cyprus Tax Department published on 16 March 2023 the bond yield rates as at 31 December 2022 for a number of countries, to be considered for the Notional Interest Deduction to which equity injected in to Cyprus companies is entitled for 2023.

Transfer Pricing Rules in Cyprus – Additional FAQs by Tax Authorities

The Cyprus Tax Department issued additional Frequently Asked Questions (FAQs) on its website, providing guidance on certain aspects of the Transfer Pricing Rules introduced with effect from 1 January 2022.  

Transfer Pricing Rules in Cyprus – FAQs by Tax Authorities

The Cyprus Tax Department issued a series of Frequently Asked Questions (FAQs) on its website, providing guidance on certain aspects of the Transfer Pricing Rules introduced with effect from 1 January 2022.

Termination of Special Tax Treatment for “Back to Back” Financing Arrangements

Through a circular issued on 5 January 2023, the Cyprus Tax Authorities announced that the provisions of circulars issued in the past about the so called “back-to-back” financing arrangements...

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