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25 September 2018

Cyprus issues announcement on Country-by-Country Reporting obligations related to CbCR exchange relationships

On 19 September 2018, the Cypriot Tax Department issued an announcement regarding Country-by-Country Reporting (CbCR) obligations related to CbCR exchange relationships as follows:

  1. Constituent entities with a Cypriot Ultimate Parent Entity (UPE) will not be subject to local filing in their jurisdiction of tax residency, provided the relevant CbC Multilateral Competent Authority Agreement (MCAA) is activated between Cyprus and the other jurisdiction.

The CbCR Activated Exchange Relationships are available on the OECD website on the following link:

  • Similarly, no obligation for local filing of CbCR tables should arise for Cypriot constituent entities with no Cypriot UPE if the MCAA is activated between Cyprus and the jurisdiction of the reporting entity.
  • An obligation for local filing will arise for Cypriot constituent entities if the exchange relationship between Cyprus and the jurisdiction where the CbC report is filed by the Multinational enterprise group is not activated for the respective fiscal year (e.g., 31 December 2017) before the CbCR deadline (e.g., by 31 December 2018 for FY 2017).
  • The tax authorities have further clarified that no exchange information agreement is expected to be signed with the United States (US) prior to 31 December 2018, thus an obligation for local filing will arise in Cyprus in cases where a group's CbCR tables are submitted in the US.
  • In cases where notifications have been filed in Cyprus by Cypriot constituent entities of multinational groups affected by this announcement, such notifications must be revised in accordance with this announcement. If such notifications are revised by the end of December 2018, no penalties will be imposed for 2017.

    • For additional information with respect to this Alert, please contact the following:

    Ernst & Young Cyprus Limited, Nicosia

    • Petros Krasaris
      petros.p.krasaris@cy.ey.com

    Ernst & Young Cyprus Limited, Limassol

    • Charalambos Palaontas
      charalambos.palaontas@cy.ey.com
    • Antonis Dimitriou
      antonis.dimitriou@cy.ey.com

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