Tag Archives: Cyprus Tax Authorities

ILN Today Post

Cyprus Tax Authorities introduce guidance for taxation of Intra-Group Financing Transactions

On 30 June 2017, the Cyprus Tax Authorities (the “CTA”) issued a tax circular (the “Circular”) with respect to the new rules for the taxation of back-to-back intra-group financing transactions. The Circular is effective as from 1 July 2017 and follows the application of the arm’s length principle set out in the OECD Transfer Pricing Guidelines.

Earlier this year, the CTA announced that, with effect from 1 July 2017, the application of the specified minimum profit spreads (0.125% – 0.35%) on qualified back-to-back related-party financing transactions will be terminated and the treatment of such transactions is now subject to the Circular.

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