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ARTICLE · 30 JANUARY 2019

Cyprus Rolls Out Anti-Tax Avoidance Directive

Elias Neocleous & Co LLC
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Interest costs disallowed by reason of the rules may be carried forward for up to five years.

CyprusTax

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.

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