With effect as from 1 January 2022, transfer pricing
documentation requirements have been introduced. The transfer
pricing documentation compliance obligations include the
preparation of Master File, Cyprus Local File, and Summary Table
for Cyprus tax resident persons and PEs of non-Cyprus tax resident
persons situated in Cyprus that engage in transactions with related
parties. A formal Advance Pricing Agreement (APA) procedure has
also been introduced. Specific penalties for noncompliance with the
new obligations are now in place.
Transfer Pricing Documentation
As from 1 January 2022, Cyprus tax resident persons and PEs of
non-Cyprus tax resident persons situated in Cyprus that engage in
domestic and/or cross-border controlled transactions, subject to
exemptions mentioned below, are required to prepare, on an annual
basis, a Transfer Pricing Documentation File, which consists of the
'Master File' and the 'Cyprus Local File'.
