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March 19, 2021

Cyprus approves legislation to implement Mandatory Disclosure Rules

On 18 March 2021, the Cypriot Parliament voted for the amendment of the Cypriot Law on Administrative Cooperation in the field of Taxation (Law N. 205(I)/2012 or the Law) implementing the European Union (EU) Directive on the mandatory disclosure and exchange of information on reportable cross-border tax arrangements (referred to as the Directive).

Once the Law is published in the Official Gazette, it will be effective as of 1 January 2021 although the Law has retroactive effect and captures reportable cross-border arrangements made on or after 25 June 2018. In addition, guidance notes (in the form of a Ministerial Decree) will be issued in the next few weeks and will provide clarity regarding the interpretation of key terms and provisions of the Law.

In general, the Law is aligned to the minimum standards set forth by the Directive with minor deviations.

The extension of the deadline for DAC6 submissions to 31 March 20211 and the non-imposition of administrative fines for DAC6 submissions made up until 30 June 20212 are not affected by the enactment of the Law.

A detailed Alert on the final provisions of the Law will follow  when the final text of the Law is made publicly available.


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

Ernst & Young Cyprus Limited, Nicosia



  1. See announcement of the Cypriot Tax Department, DAC6 – Οδηγ?α του Συμβουλ?ου της ΕΕ για την υποχρεωτικ? αποκ?λυψη και ανταλλαγ? πληροφ?ρησης για διασυνοριακ?ς ρυθμ?σεις’, dated 3 February 2021.

  2. See announcement of the Cypriot Tax Department, DAC6 – Οδηγ?α του Συμβουλ?ου της ΕΕ για την υποχρεωτικ? αποκ?λυψη και ανταλλαγ? πληροφ?ρησης για διασυνοριακ?ς ρυθμ?σεις’, dated 26 February 2021.


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