The Cyprus Parliament voted on 5 April 2019 the first
implementation law in Cyprus of the EU Anti- Tax Avoidance
Directive (ATAD) and more specifically on the following areas:
1. Interest limitation rule
2. Controlled Foreign Company (CFC) rule
3. General Anti-Abuse rule (GAAR)
The first ATAD implementation law will enter into force on the
date that it will be published in the Cyprus Government Gazette
with an effective date as from 1 January 2019 i.e. for tax years
2019 and onwards.
The first ATAD implementation law impacts only Cyprus corporate
income tax taxpayers (Cyprus CIT taxpayers) and more
specifically:
- Cyprus tax resident companies,
and
- Cyprus permanent establishments (PEs)
of non-Cyprus tax resident companies
