EU AntiTax Avoidance Directive (ATAD)

The Cyprus Parliament voted on 5 April 2019 the first implementation law in Cyprus of the EU AntiTaxAvoidance Directive (ATAD) and specifically on the following areas:

• Controlled Foreign Company (CFC) rule –effective date 01 January 2019
• (Net) Interest limitation rule –effective date 01 January 2019
• General Anti-Abuse rule (GAAR) –effective date 01 January 2019
• Exit taxation provisions –effective date 01 January 2020
• Hybrid mismatch rules –effective date 01 January 2020(exception: certain reverse hybrid mismatch provisions -01 January 2022)

The first ATAD implementation law will enter into force once it is published in the Cyprus Government Gazette with an effective date as from 1 January 2019.