Copying and distributing are prohibited without permission of the publisher

Cyprus: Changes anticipated on acceptable profit margins between related companies

26 April 2017

Email a friend
  • Please enter a maximum of 5 recipients. Use ; to separate more than one email address.


Maria Nicolaou Zoe Kokoni

The Cyprus tax authorities, taking into consideration the international developments (OECD/G20 initiative – BEPS), have decided to amend the tax regime in relation to profit margins on loans between related parties.

Specifically, it is expected that as of July 1 2017, all loans between Cyprus tax resident companies and their related companies, will now have to be supported by transfer pricing studies. These will have to be prepared by independent experts and be based on the OECD principals. This new rule will affect all the financial transactions between related companies for both tax assessment purposes and for the issuance of tax rulings.

In addition, all tax rulings that have been issued up to June 30 2017 in relation to this subject will become void.

As a result of the above, we strongly advise clients and other interested parties to start reviewing their group structures.

Maria Nicolaou (maria.nicolaou@eurofast.eu) and Zoe Kokoni (zoe.kokoni@eurofast.eu), Nicosia
Eurofast Taxand Cyprus
Tel: +357 22699222
Website: www.eurofast.eu






International Tax Review Profile

RT @BrigitteAlepin: So proud of the new book WINNING THE TAX WARS. Bringing together well-known tax experts, this book presents outstanding…

Dec 7 2017 04:08 ·  reply ·  retweet ·  favourite
International Tax Review Profile

REVEALED: The top 10 of ITR's #GlobalTax50 2017 is out now. Find it here: https://t.co/IXiaRrE3vH (subscription or free trial required)

Dec 7 2017 01:42 ·  reply ·  retweet ·  favourite
International Tax Review Profile

ITR has opened the submissions period for the European Tax Awards 2018. Full details here: https://t.co/WKBWijhBgt

Dec 6 2017 01:40 ·  reply ·  retweet ·  favourite
International Tax Review Profile

@aloysrigaut @AuroChardon @ElodieLamer @JeanComte @diego_bxl @bsmithmey @afpfr @pierremoscovici @EU_Taxud @EU2017EE… https://t.co/oS4sDvQtdL

Dec 5 2017 04:55 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @AuroChardon: Is this it? https://t.co/O1XhoWQw2F 17 #taxhavens, mostly tiny countries or emerging economies on the #EUblacklist? ❌Swit…

Dec 5 2017 02:25 ·  reply ·  retweet ·  favourite
International Correspondents