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04 January 2019
On 22 November 2018 the Tax Department announced that constituent entities of Cyprus ultimate parent entities (UPEs) will not be subject to local filing in their jurisdiction of tax residence, provided that the tax information exchange arrangement under the Common Reporting Standard Multilateral Competent Authority Agreement has been activated. In addition, local filing will not be applicable for Cyprus-resident constituent entities which have no Cyprus tax resident UPEs.(1)
The Tax Department did not expect a tax information exchange agreement with the United States to be in place by the reporting deadline of 31 December 2018, which means that local filing obligations will arise in Cyprus for constituent entities of groups which submit their country-by-country report in the United States.
Any notifications submitted in error by Cyprus-resident constituent entities affected by the announcement should be revised in accordance with the announcement. No penalties will be imposed in respect of notifications for 2017 if they were corrected by 31 December 2018.
For further information on this topic please contact Natasa Polyviou at Elias Neocleous & Co LLC by telephone (+357 25 110 110) or email (firstname.lastname@example.org). The Elias Neocleous & Co LLC website can be accessed at www.neo.law.
(1) See a list of currently activated exchange relationships here.
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