Introduction of Transfer Pricing Documentation Requirements in
Cyprus
On 30th June 2022 the Cyprus Parliament approved the long awaited
amendments to the Cyprus Income Tax Law and new Regulations to
introduce Transfer Pricing ("TP") documentation
compliance obligations which closely follow the OECD TP Guidelines
(as amended from time to time).
The amendments to the Income Tax Law and new
regulations are summarised as follows:
1. Definition of Related Parties
In a nutshell two companies are considered as related
if the same person (and its related persons) or group(s) of persons
(under certain conditions) directly or indirectly:
- hold 25% of the voting rights or share capital ofboth
companies, or
