Taxation

Residential Permit for third – country nationals: new changes

On 01.01.2023 the new changes in the application for the temporary residential permit for the third country – nationals, those who are outside of EU, (“Visitor”) in Cyprus will come into effect, meaning that the following additional requirements should be satisfied: Detailed statement of bank account transactions in a financial institution in the Republic of …

Residential Permit for third – country nationals: new changes Read More »

UBO Reporting: breach of personal rights

On 22 November 2022 the Court of Justice of the European Union (“CJEU”) ruled that the provision of Directive (EU) 2015/849 establishing that all Member States must ensure that information on the beneficial ownership of legal entities is accessible in all cases to any member of the general public is invalid and in conflict with …

UBO Reporting: breach of personal rights Read More »

Unpaid Annual Levy and possible strike off

On 3 November 2022 the Department of Registrar of Companies and Intellectual Property (“ROC”) announced that it intends to proceed with the 𝐝𝐞𝐫𝐞𝐠𝐢𝐬𝐭𝐫𝐚𝐭𝐢𝐨𝐧 𝐨𝐟 𝐜𝐨𝐦𝐩𝐚𝐧𝐢𝐞𝐬, 𝐢𝐟 𝐭𝐡𝐞𝐲 𝐟𝐚𝐢𝐥𝐞𝐝 𝐭𝐨 𝐬𝐞𝐭𝐭𝐥𝐞 𝐭𝐡𝐞 𝐩𝐚𝐲𝐦𝐞𝐧𝐭𝐬 𝐟𝐨𝐫 𝐚𝐧𝐧𝐮𝐚𝐥 𝐥𝐞𝐯𝐲. The ROC may remove a company from the register if the company fails to pay the annual fee provided for …

Unpaid Annual Levy and possible strike off Read More »

Tax Exemptions on the First Employment: Clarifications

On 01.11.2022 the Tax Department has issued the Circular (Νο. 10/2022) for the purposes of clarifying new tax income exemptions for the practical application as well as conceptualizing the term “first employment”. By virtue of the Circular, it should be noted that the first employment of an individual ceased to exist or never existed in …

Tax Exemptions on the First Employment: Clarifications Read More »

Clarification on Bilateral Agreement between Cyprus and United States

On 13.10.2022 the Cyprus Tax Department notified all legal entities and their official representatives that the Bilateral Competent Authority Arrangement (CAA) for the exchange of Country-by-Country (CbC Reports) between Cyprus and the United States of America for Reporting Fiscal Years will be effective on or after 01.01.2022. As a result, if the Ultimate Parent Entity …

Clarification on Bilateral Agreement between Cyprus and United States Read More »

Provisional Tax Liability by Newly Incorporated Companies

According to the recent interaction between the Commissioner of Taxation and the Tax Compliance Committee of ICPAC (“The Institute of Certified Public Accountants of Cyprus”), no penalties or interest should be imposed on the entity which was incorporated within the period from 31.07.2022 (first installment of the provisional tax) to 31.12.2022 ( second installment) in …

Provisional Tax Liability by Newly Incorporated Companies Read More »

EU COMMISSION PROPOSED DIRECTIVE ON SHELL ENTITIES

On 22 December 2021, the European Comission published the Proposal for a Council Directive 2021/0434, also known as the Anti tax Directive III („ATAD III“), with the stated intention being to prevent the misuse of so-called „shell“ entities for the tax purposes. ATAD III  aims to highlight the importance  of minimal substance requirements and is  applicable to …

EU COMMISSION PROPOSED DIRECTIVE ON SHELL ENTITIES Read More »

Additional Corporate Tax Residency Test – our remarks

On 21.12.2021, amendment 193(I)/2021 to the Income Tax Law has been published in the Official Gazette of the Republic of Cyprus by adopting an additional test for determination of corporate tax residency based on the incorporation principle. The new amendments will come into force on 31 December 2022. It provides that any company having its …

Additional Corporate Tax Residency Test – our remarks Read More »

Cyprus Tax Incentives 2022 IBCCS TAX International Tax Planning

New Tax Incentives for first employment in Cyprus

On 26.07.2022, new amending provisions under Articles 8(21) and 8(23) of the Income Tax Law have been published in the Official Gazette of the Republic of Cyprus, which establish 50% tax exemption for the first employment income under certain conditions: Prior to the commencement of employment in Cyprus, the employee should not be a tax …

New Tax Incentives for first employment in Cyprus Read More »

IBCCS TAX Cyprus Provisional Tax 2022 First instalment transfer pricing

New Transfer Pricing Law Amendments and Regulations in Cyprus

Transfer Price is a practice in accounting occurring when goods or services are exchanged between divisions (subsidiaries, affiliates, or commonly controlled companies) of the same larger entity On 30 June 2022 the House of Representatives voted on and approved amendments to the Income Tax Law and the Assessment and Collection of Taxes Law (TP legislation). …

New Transfer Pricing Law Amendments and Regulations in Cyprus Read More »