Cyprus introduces transfer pricing rules and documentation requirements

On 30 June 2022, the Cyprus Parliament enacted amendments to the Income Tax Law and the Assessment and Collection of Taxes Law in relation to transfer pricing regulations in accordance with recommendations of the Organisation for Economic Co-operation and Development on Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (OECD TP Guidelines).

The laws will be effective as of 1 January 2022 and once published in the official Gazette.

As per the amended Law, the new TP rules apply to transactions between related parties (legal persons and individuals). For corporate entities, the new law provides detailed rules as to the meaning of the term “related parties” in an effort to capture different relations that there is a “control” situation.

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