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Announcement Regarding CbCR Obligations Related to CbCR Exchange Relationships Issued by Cyprus Tax Department

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The Cyprus Tax Department issued an announcement regarding Country-by-Country Reporting (CbCR) obligations related to CbCR exchange relationships on September 19 2018, which is available to view herewhilst the CbCR Activated Exchange Relationships are available to view on the OECD website.

Pertinent points of the announcement (in brief) include:

Penalties: No penalties will be imposed for 2017 in the case that notifications filed in Cyprus by Cypriot constituent entities of multinational groups affected by this announcement revise the notifications by the end of December 2018 - in accordance with the announcement.

US: No exchange information agreement is expected to be signed with the United States (US) prior to December 31, 2018. As such, in cases where a group’s CbCR tables are submitted in the US, there is an obligation for local filing in Cyprus.

Cypriot constituent entities:

  • If the exchange relationship between Cyprus and the jurisdiction where the CbC report is filed by the Multinational enterprise group is not activated for the respective fiscal year (e.g., December 31, 2017) before the CbCR deadline (e.g., by December 31, 2018 for FY 2017), an obligation for local filing will arise for Cypriot constituent entities.
  • Provided the relevant CbC Multilateral Competent Authority Agreement (MCAA) is activated between Cyprus and the other jurisdiction, constituent entities with a Cypriot Ultimate Parent Entity (UPE) will not be subject to local filing in their jurisdiction of tax residency.
  • If the MCAA is activated between Cyprus and the jurisdiction of the reporting entity, there is no obligation for local filing of CbCR tables for Cypriot constituent entities with no Cypriot UPE.