Cyprus Transfer Pricing 2026: A Practical Guide For Group Controllers

The Cyprus transfer pricing landscape changed materially with N.244(I)/2025, which amended Article 33 of the Income Tax Law as part of the broader 2026 reform package. From 1 January 2026, the thresholds that determine whether your Cyprus subsidiary must keep a Cyprus Local File have been raised significantly. Many group controllers will read this as good news.

It is. But not in the way most people assume.

The new Cyprus transfer pricing 2026 thresholds remove the Local File burden for a large number of medium-sized subsidiaries. They do not remove the obligation to apply the arm’s length principle. They do not remove the requirement to file the Summary Information Table. And they do not remove the requirement to keep minimum transfer pricing documentation on file. This is the practical guide your finance team needs.