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| 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