31 December 2022 is the submission
deadline for the following Country-by-Country (CbC) Reporting obligations in
Cyprus:
- Submission of CbC Reports for the 2021 Reporting Fiscal Year (in
respect of Multinational Enterprise (MNE) groups which have a year end of 31
December 2021)
- Submission of CbC Notifications for the 2022 Reporting Fiscal Year,
(in respect of MNE groups which have a year end of 31 December 2022).
For accounting years which are not the same with the calendar year
different deadlines apply.
It is reminded that a Cyprus company which is a member of a reportable
international group can be reported in one of the following ways:
- As an ultimate parent entity, in which case it must
electronically notify the Tax Department confirming that it is the CbC
reporting entity of the Group.
- As a surrogate parent entity, in which case it must
electronically notify the Tax Department confirming that it is the CbC
reporting entity for the Group. It must also provide the identity and tax
residence of the Group’s ultimate parent entity.
- As a domestic constituent entity (“CE”), in which case
it must electronically notify the Tax Department confirming the identity and
tax residence of the CbC reporting entity of the Group. It must also provide
the identity and tax residence of the Group’s ultimate parent entity (if
different from the reporting entity).
It is also reminded that CbC
Reporting applies to large MNE groups with annual consolidated group revenue of
€750 million or more in the previous fiscal year.
A penalty of up to €10,000 in
respect of Reports and €5,000
in respect of Notifications, may
be imposed on a Cyprus company with a duty to report/notify for late filing.
Under certain circumstances the penalty can increase up to €20,000.