Cyprus tax news on Cyprus Companies' intra-group
financing transactions (New Cyprus transfer pricing rules on Cyprus
Companies' intra-group financing transactions)
General
The Cyprus Tax Department has issued a circular for the tax
treatment of intra-group financing transactions (Cyprus transfer
pricing rules on intra-group financing transactions). The term
intra-group financing transaction (transfer pricing rules on
intra-group financing transactions) refers to any activity
consisting in the granting of loans, debentures, or cash advances
remunerated by interest to related companies (Related companies are
defined as the relationship between two companies for instance that
of holding company and subsidiary company or the relationship
between associated companies where there is control on the
composition of board of directors, holding the majority of the
voting rights etc).
