The New Transfer Pricing (TP) Legislation In Cyprus & Its Expected Impact

Introduction

On 30 June 2022, Cyprus has introduced provisions for implementation of transfer pricing regulations in Cyprus by amending the current Cypriot Income Tax & Assessment and Collection laws. The effective date of the TP legislation is the 1 January 2022.

The main purpose of the introduction of the TP legislation is the alignment of the Cypriot Tax laws with OECD guidelines against Base Erosion and Profit Shifting (BEPS project). The amendments introduce guidelines on assessment of transactions between related parties for arm's length purposes and provide the legal basis for the conclusion of Advance Pricing Agreements (APAs).

Amendments of the Income Tax Law

The changes mainly affect the article 33 of the Income Tax Law, which is the article dealing with transactions between related parties.