The Cyprus Tax Department through an announcement informs all
legal entities and their representatives that the bilateral
Competent Authority Arrangement (CAA) for the exchange of
Country-by-Country (CbC Reports) between Cyprus and the United
States of America, which is currently under negotiation, is
expected to be effective for Reporting Fiscal Years starting on or
after 1 January 2023.
Consequently, in the case where the Ultimate Parent Entity of a
Multinational Group of Enterprises (MNE) is tax resident in the
United States of America, the secondary filing mechanism should be
triggered for Reporting Fiscal Years starting on or after 1 January
2022 and before 1 January 2023.
For example, a local filing obligation should still arise in
Cyprus in respect of an MNE Group's CbC report for Reporting
Fiscal Year ending on 31 December 2022, even if a CbC Report has or
will be submitted in the United States of America.
