Cyprus tax authorities issue transfer pricing guidance on the pricing of 'back-to-back' financing transactions

17 July 2023|Tax Alerts, Information Reporting, Legislation & Policy, National/Federal Taxation, Transfer Pricing, OECD, BEPS 2.0|Cyprus

On 7 July 2023, the Cypriot Tax Department issued a tax circular, effective retrospectively as of 1 January 2023, providing guidance on determining arm's-length pricing for "back-to-back" financing transactions.
This Alert highlights the requirements outlined in the tax circular.

Executive summary

The Cypriot Tax Department issued a circular (Circular) on 7 July 2023, with effect as of 1 January 2023, indicating that Comparable Uncontrolled Price (CUP) is the most appropriate documentation method f…

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