31 December 2019 is the submission deadline for the following Country-by-Country (“CbC”) Reporting obligations in Cyprus:
- Submission of CbC Reports for the 2018 Reporting Fiscal Year (in respect of Multinational Enterprise (“MNE”) groups which have a year end of 31 December 2018)
- Submission of CbC Notifications for the 2019 Reporting Fiscal Year (in respect of MNE groups which have a year end of 31 December 2019).
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).
A penalty of up to EUR10,000 in respect of Reports and EUR5,000 in respect of Notifications, may be imposed on a Cyprus company with a duty to report/notify for late filing. Under certain circumstances a penalty can increase up to EUR20,000.
