Cyprus Introduces Rules To Implement Country By Country Reporting Requirements

The Cyprus Minister of Finance issued a Decree on 30 December 2016, introducing a mandatory Country by Country (CBC) reporting requirement for multinational enterprise groups generating consolidated annual turnover exceeding €750m (MNE Group). The Decree is compliant with the EU Directive 2016/881 amending Directive 2011/16 relating to mandatory automatic exchange of information in the field of taxation and the OECD BEPS Action 13 on transfer pricing documentation and country by country reporting.

Consequently, MNE Groups with an ultimate Cyprus tax resident parent, are required to annually file a Country by Country report which includes specific financial data covering income, taxes, and other key measures of economic activity by territory. Cyprus tax resident entities belonging to an MNE group that has a non-Cyprus tax resident ultimate parent may under certain conditions be obliged to submit a CBC report in Cyprus (under the secondary filing mechanism) or be