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11 May 2018
The recently introduced Law 33(I)/2018 amends the Law regarding Administrative Cooperation in the Field of Taxation 2012 to 2017(1) in order to align domestic law with EU Directive 2016/881/EU, which amended EU Directive 2011/16/EU on administrative cooperation in the field of taxation.
The amending law replaces the definition of 'automatic exchange' contained in Article 2 of the principal law with the revised definition set out in Article 1 of EU Directive 2016/881/EU. It also adds a new Article 7C, which requires ultimate parent entities of multinational enterprises (MNEs) resident in Cyprus for tax purposes, and other reporting entities under Annex III of the law, to file country-by-country reports within 12 months of the end of each fiscal year. The first fiscal year for which a country-by-country report must be filed is that beginning on or after January 1 2017.
The required format for a country-by-country report is set out in Annex III and comprises:
As the competent authority under the law, the Cyprus Tax Department must notify its counterparts in other EU member states of any information relating to a constituent entity resident in another member state within 15 months from the end of the reporting period.
In addition, the new law introduces the other detailed technical amendments contained in the amended EU directive.
For further information on this topic please contact Elena Christodoulou at Elias Neocleous & Co LLC by telephone (+357 25 110 110) or email (email@example.com). The Elias Neocleous & Co LLC website can be accessed at www.neo.law.
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