<\/p>\n
Important amendments have been introduced to Cyprus tax legislation regarding Transfer Pricing (TP). The changes were made to the Income Tax Law No. 118(I)\/2002, Article 33, and affect documentation and reporting obligations for controlled transactions.<\/p>\n
The obligation to prepare detailed transfer pricing documentation (Local File) applies when the volume of controlled transactions with related parties during a calendar year exceeds the following thresholds:<\/p>\n
\u20ac10,000,000 \u2014 financial transactions (loans and borrowings)<\/p>\n<\/li>\n
\u20ac5,000,000 \u2014 sale or purchase of goods<\/p>\n<\/li>\n
\u20ac2,500,000 \u2014 services, intellectual property, and other transactions<\/p>\n<\/li>\n<\/ul>\n
While the thresholds for documentation have been revised, the requirement to disclose all controlled transactions remains unchanged.<\/p>\n
Regardless of whether the above thresholds are exceeded, taxpayers are required to submit the Summary Information Table (SIT) on an annual basis.<\/p>\n
Important:
The SIT must be filed for all controlled transactions without exception, even where the transaction amount is as low as \u20ac1.
Transactions that do not meet the Local File threshold must still be disclosed in the SIT.<\/p>\n
According to the current regulations, the deadline for submitting the SIT for the 2024 reporting year is 30 November 2026.<\/p>\n
Cyprus tax legislation \u043f\u0440\u0435\u0434\u0443\u0441\u043c\u0430\u0442\u0440\u0438\u0432\u0430\u0435\u0442 significant penalties for non-compliance with Transfer Pricing requirements:<\/p>\n
Failure to submit or late submission of the SIT \u2014 \u20ac500 (fixed penalty)<\/p>\n<\/li>\n
Failure to provide the Local File upon request by the tax authorities (within 60 days) \u2014 penalties ranging from \u20ac5,000 to \u20ac20,000, depending on the length of the delay<\/p>\n<\/li>\n<\/ul>\n
Timely compliance with TP requirements helps reduce tax risks and avoid penalties.<\/p>\n
<\/p>\n
Note: The content of this article is relevant at the time of its first publication. It is intended to provide general information on the topic and does not constitute legal advice. We recommend seeking professional advice regarding your specific matter before taking action based on the information presented. For more information or consultation, please contact our tax experts by email at\u00a0<\/span><\/i>contact@mainpartnertrust.com<\/span><\/i><\/a><\/p>\n See more at\u00a0<\/em>Instagram<\/em><\/a>,\u00a0<\/em>https:\/\/t.me\/mainpartnertrust<\/em><\/a>\u00a0\u00a0<\/em><\/p>","protected":false},"excerpt":{"rendered":" Updates to Transfer Pricing Rules in Cyprus Important amendments have been introduced to Cyprus tax legislation regarding Transfer Pricing (TP). The changes were made to the Income Tax Law No. 118(I)\/2002, Article 33, and affect documentation and reporting obligations for controlled transactions. New thresholds for Local File preparation The obligation to prepare detailed transfer pricing […]<\/p>\n","protected":false},"author":3,"featured_media":2253,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[1,2,3,4],"tags":[],"class_list":["post-2250","post","type-post","status-publish","format-standard","has-post-thumbnail","hentry","category-bez-rubriki","category-blog","category-media","category-news"],"aioseo_notices":[],"aioseo_head":"\n\t\t\n\t\n\t\n\t\n\t\n\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t\n\t\t