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Transfer Pricing - Circular 6/2023
The Cyprus Tax Department (“CTD”) issued a Circular on 6 July 2023 (the “Circular”),
with retrospective effect as of 1 January 2022, introducing Minimum TP Documentation
requirements and simplification measures regarding intra-group transactions which are
below the threshold of €750,000 in aggregate per category of transaction per tax year.
Furthermore, Optional Simplification Measures allowing the application of Safe
Harbours have been introduced with regards to specific sub-categories of intra-group
transactions,
provided that adequate level of documentation is maintained.
Transfer Pricing - New Thresholds for the Preparation of Local Files
On 1 February 2024, the Cyprus Tax Department (“CTD”), announced the increase of the materiality threshold for the preparation of a Cyprus Local File for the tax year 2022 onwards.
The Local File focuses on information relevant to the Transfer Pricing Study, covering transactions between related parties, including relevant financial information, a comparability analysis and the selection and application of the most appropriate TP method.
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