Currently, the Transfer Pricing (“TP”) law and regulations cover all type of transactions between related parties (that meet the 25% relationship test) in excess of €750.000 per category of transactions.
Type of transactions covered:
- Provision and receipt of finance;
- Sale and purchase of goods;
- Provision and receipt of services;
- IP related (sale, purchase, leasing of intangible assets).
Following various discussions between the stakeholders, the below revised thresholds have been announced by the Ministry of Finance:
- The threshold for the financing transactions category from €750.000 to €5.000.000. It shall be noted that for threshold purposes, the principal amount including interest charged but not paid is taken into account.
- The threshold for all other categories from €750.000 to €1.000.000 (i.e. services, goods, IP related etc.)
Simplification Measures – Circular 6/2023
Reference is also made in the letter, highlighting that any persons that are exempted from the obligation to prepare a Cyprus Local File to document their intra-group transactions, are required to comply and be in line with the provisions of Circular 6/2023, containing minimum TP documentation requirements for controlled transactions that do not exceed the aforementioned thresholds.
Throughout the discussions, all stakeholders and involved parties shared a common intention of revising the existing thresholds, with the primary goal of achieving a more simplified and streamlined tax system, in terms of the documentation required for TP purposes.
The collective aim was to alleviate the compliance burden placed on Cyprus taxpayers. Recognizing the complexities and challenges within the existing framework, the parties involved actively sought to create amendments that would not only simplify processes but also contribute to a more efficient and transparent taxation system.
The collaborative efforts reflected a commitment to ensuring that the legislative changes would facilitate a smoother and more accessible tax environment for all concerned parties.
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