Cyprus Intra-Group Financing | Transfer Pricing

This is a general review of requirements introduced by the Cyprus Tax Department in the Interpretative circular of 30^th of June (which came into effect from July 1^st 2017 for all existing and future transactions, irrespective of the date of entering into the relevant transactions and irrespective of any tax rulings effective prior to the above date) setting out the revised tax treatment of intra-group back-to-back financing arrangements. This Circular sets out the requirements for companies that are either Cyprus tax resident (namely companies whose management and control are exercised in Cyprus), or are tax resident outside Cyprus but have a permanent establishment in Cyprus, and carry out group financing transactions.