On 24 January 2022, the Cyprus Tax Authority (CTA) issued Frequently Asked Questions (FAQs) with reference to the Interpretive Circular 3 dated 30 June 2017 with title "Tax treatment of intra-group back-to-back financing transactions" (Back-to-Back Circular).
The Back-to-Back Circular, which is effective from 1 July 2017, provides guidance in terms of substance and transfer pricing (TP) documentation requirements with respect to on-lending financing transactions.
The answers to the FAQs are applic…