120 results found

In Cyprus Transfer Pricing rules are regulated by the circular issued on 30 June 2017 by the Cyprus Tax Authorities (CTA) (the "Circular") revising the transfer pricing framework for companies ...

The Quality Assurance Audit Certification for the Cyprus Transfer Pricing Documentation File is a mandatory requirement under Cyprus tax law. It ensures that companies...

The Transfer Pricing rule is the method whereby tax law allocates income to related companies and permanent establishments.

This is a general review of requirements introduced by the Cyprus Tax Department in the Interpretative circular of 30th of June setting out the revised tax treatment of intra-group back-to-back financing arrangements.

Bringing Cypriot Income Tax Law in line with the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations and within the framework of Action 13 of the BEPS action plan.

Interest costs disallowed by reason of the rules may be carried forward for up to five years.

Transfer pricing often first appears to be an accounting question. The legal position matters just as much. A payment between companies in the same group may be recorded correctly in the accounts and still need to be tested against the terms independent parties would have agreed.

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...

Apart from implementation of EU directives, amendments to the Cyprus tax laws are generally infrequent.

A major change is expected to incur by the end of 2020 in the tax environment at an international level, since the new tax rules on digital economy will be finalised.

On 6 July 2023, the Cyprus Tax Department released a new Circular (6/2023) titled "Simplification measures for persons that are exempt from the obligation to maintain a Cyprus Local File".

On 1 February 2024, the Cyprus Tax Department ("CTD") issued a Circular with retrospective effect as of 1 January 2022 and onwards, announcing the increase of the materiality threshold...

The UAE introduced Transfer Pricing ("TP") regulations as part of its Corporate Tax Law under Federal Decree-Law No. 47 of 2022, which applies to tax periods starting on or after 1 June 2023.

In December 2025, the House of Representatives approved amendments to the Income Tax Law of 2002 (as amended) ("ITL"), forming part of a broader tax reform initiative.

On September 10, 2024, the Court of Justice of the European Union ("CJEU") issued a decisive judgment in the long-running battle between Apple, Ireland, and the European Commission...

Further to the recent amendments introduced in Cyprus as to the Tax Treatment of intra-group back-to-back Financing Agreement, as of the end of June 2017 the Tax Department in Cyprus has released its Circular as to its interpretation of these new provisions.

As multinational companies face increasingly complex tax rules, economic substance requirements, and cross-border employment challenges, advisory firms are adopting digital twin models...