On 10 February 2023, the Cyprus Tax Department (CTD) issued a new page named “Frequently Asked Questions” (FAQs) on its official website, pertaining to transfer pricing.
The FAQs aim to provide preliminary guidance on select aspects of the Transfer Pricing documentation rules that were introduced in the previous year. Specifically, it is clarified that Interpretive Circular 3 dated 30 June 2017 with respect to back to back financing transactions (which under certain conditions provided for a safe harbour return of 2% after tax on assets) no longer applies as from 1 January 2022.
We remain at your disposal to address any further inquiries you may have.
