Cyprus

Transfer pricing news, BEPS news, and international tax news in Cyprus

Cyprus extends DAC6 penalty relief

Posted on by in Cyprus, Europe, Latest, Multinational Tax, OECD, Tax, Tax Avoidance and tagged .
Cyprus extends DAC6 penalty relief

On March 18, 2021, the Government approved Law to require taxpayers/ intermediaries to report information on certain tax arrangements. 

Cyprus extend DAC6 penalty relief

The Cyprus Tax Department will not impose administrative fines for overdue submission of DAC6 information that will be submitted until the September 30, 2021.

The penalty relief applies to:

  • Reportable cross-border arrangements that have been made between 25 June 2018 and 30 June 2020 and had to be submitted by 28 February 2021.
  • Reportable cross-border arrangements that had been made between 1 July 2020 and 31 December 2020 and had to be submitted by 31 January 2021.
  • Reportable cross-border arrangements made between 1 January 2021 and 31 August 2021, that had to be submitted within 30 days from the date they were made available for implementation or were ready for implementation or the first step in the implementation has been made, whichever occurred first.
  • Reportable cross-border arrangements for which secondary intermediaries provided aid, assistance or advice, between 1 January 2021 and 31 August 2021 and had to submit information within 30 days beginning on the day after they provided aid, assistance or advice.

On March 18, 2021, the Government approved Law to require taxpayers/ intermediaries to report information on certain tax arrangements. 

Transfer Pricing Compliance in China: Preventing Disputes is Key

Posted on by in Asia Pacific, BEPS, China, Cyprus, Latest, Transfer Pricing and tagged .

China’s colossal economy and its predominant role within the global market result in the emergence of an increasing interest towards China’s transfer pricing regime. Since China is not a member of the OECD, any transfer pricing endeavor goes far beyond the classic transfer pricing practices, though.Continue Reading

Liberia: Where Transfer Pricing is in Full Bloom

Posted on by in Cyprus, Europe, Latest, Transfer Pricing and tagged .

Liberia is a typical example amongst developing African countries making noticeable effort to expand their tax base to the size it should appropriately be, therefore collecting more taxes and adapting to the fast-changing local and global business environment.Continue Reading

Transfer Pricing: The Intangible Assets Case

Posted on by in Cyprus, Europe, Latest, Transfer Pricing and tagged .

Introduction

The transfer pricing of intangible properties has always been a significant issue for multinational enterprises (MNEs). The excellent idea devoted to this matter with the current drive of the OECD to counter tax base erosion is dim long over-due. Indeed, the case with transfer pricing is technically considered a neutral concept but erroneously taken as an offensive action of MNEs that permits them to transfer profits generated by intangibles to so-called tax havens. Although, the arm’s length principle enshrine in the OECD Model has been misidentified as the primary instrument to tackle such abusive behavior of MNEs.Continue Reading

CCCTB: The concept and the effects in Cyprus and Malta

Posted on by in BEPS, Cyprus, Europe, Latest, Transfer Pricing and tagged .

Introduction

When states attain membership of the European Union (EU), the governments are in charge of enacting and implementing their local direct taxation policy. The tax framework of the member-states shall not contravene or interfere the laid down policies and directives of the EU institutions; therefore, the sovereignty of member states is extremely safeguarded. Although the EU faces difficulties to come up with results that would be generally accepted by all member states, it has taken every step to integrate all Member States’ corporate direct taxation systems since the 1950s.Continue Reading

MNEs Using Irish, Dutch Tax Systems to Avoid Tax: Commission Report

Posted on by in Cyprus, Europe, Ireland, Latest, Luxembourg, Netherlands, Transfer Pricing and tagged .
MNEs Using Irish, Dutch Tax Systems to Avoid Tax: Commission Report

The author is Alex Hunter, Editor, TP News. He oversees and updates the publication and also  regularly writes news stories about transfer pricing and international tax law. Alex is reachable on email (editor@transferpricingnews.com) and by phone (+447808558597). 

In a first, the European Commission has stressed that tax rules in seven EU member states facilitate corporate tax avoidance by multinational enterprises (MNEs).Continue Reading

Applying the Transfer Pricing CUP Method

Posted on by in Cyprus, Europe, Latest, Transfer Pricing and tagged .

The arm’s length principle treats the members of a multinational enterprise (MNE) as operating in separate entities, rather than as inseparable parts of a single, unified business. Therefore, it is required that MNEs follow the same pricing policy for intra-group and uncontrolled transactions, under comparable circumstances. Otherwise, the controlled companies shall take the necessary measures and adjust their profits by reference to the conditions, which would have obtained between independent enterprises.Continue Reading