Avoidance Directive, 2019 will be the first year in which the
Cyprus tax authorities have to deal with the new provisions for
interest on back-to-back inter-company loans, which took effect on
July 1, 2017.
This follows a quiet 2018 for new tax developments in Cyprus.
New double taxation agreements were concluded with Saudi Arabia and
Andorra, and a revised agreement was concluded with the U.K., and
re-revised before the year was out. New or revised agreements with
Luxembourg, Mauritius and San Marino, which had been signed in
earlier years, entered into force during 2018 and took effect from
the beginning of 2019.
Implementation of ATAD
Draft legislation has been published to implement the Anti-Tax
Avoidance Directive (_ATAD_) and is expected to be enacted early in
the new year, with most provisions taking retrospective effect from
the beginning of the 2019 tax year. The main features are as
follows.