The Cyprus Tax Department announced on 22 November that Constituent Entities of Cyprus Ultimate Parent Entities will not be subject to local filing in their jurisdiction of tax residence, provided the information exchange arrangement under the CRS Multilateral Competent Authority Agreement has been activated. In addition, local filing will not be applicable for Cyprus-resident Constituent Entities with no Cyprus tax resident UPE.
Activated exchange relationships are available on the OECD website on the following link
The Tax Department does not expect an exchange information agreement with the USA to be in place by the reporting deadline of 31 December 2018, which means that local filing obligations will arise in Cyprus for constituent entities of groups which submit their Country by Country Report in the USA.
Any notifications submitted in error by Cyprus-resident Constituent Entities affected by the announcement should be revised in accordance with the announcement. No penalties will be imposed in respect of notifications for 2017 if they are corrected by 31 December 2018.
For further information please contact Constantinos Christofi or your usual contact at Elias Neocleous & Co LLC.
