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ARTICLE · 01 OCTOBER 2020

The Cyprus Anti-Tax Avoidance Directive (Exit Taxation)

The Cyprus Parliament on 19 June 2020 has voted the Cyprus transposition of the European Union (EU) Anti-Tax Avoidance Directive (ATAD) for Exit taxation and Hybrid mismatch rules.

CyprusTax

The Cyprus Parliament on 19 June 2020 has voted the Cyprus transposition of the European Union (EU) Anti-Tax Avoidance Directive (ATAD) for Exit taxation and Hybrid mismatch rules, which essentially completes Cyprus' transposition of the EU ATADs i.e. ATAD I and II that were adopted by the EU in 2016 and 2017 respectively.

The new law mainly addresses Exit Taxation with the sole purpose to prevent companies from avoiding tax in the event of re-location of assets.

Our Views

While the EU Anti-Tax Avoidance Directive aims to ensure that member states take a coordinated stance against tax avoidance, it is worth to note that those targeted are Companies operating across international borders. In view of this, most of Cyprus firms have the activity of a holding company, which are tax exempt in Cyprus and with limited transactions, therefore the impact may not be that large in terms of exit taxation. We believe that the new law shall affect Companies in structures with

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