September 12, 2019


On 30 June 2017, the Cyprus Tax Department (CTD) issued a Circular revising the transfer pricing framework for companies carrying out intra-group financing activities in Cyprus. The Circular provides additional guidance in terms of substance and transfer pricing requirements in line with the Organization for Economic Co-operation and Development (OECD) Guidelines, as well as guidance as to the required content of a Transfer Pricing study. The Circular is effective from 1 July 2017 and replaces the Minimum Margin Scheme regime applicable until 30 June 2017 (of 0.125% to 0.35% for “back to back loans”).

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