Cyprus: Decree adopting country-by-country reporting; notification extended to October 2017

Country-by-country reporting in Cyprus

The Ministry of Finance in late December 2016 issued a decree to align provisions of Cypriot tax law with the requirements of EU Council Directive (EU) 2016/881 adopting the recommendations of the OECD base erosion and profit shifting (BEPS) Action Plan 13 on country-by-country (CbC) reporting.

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Based on the provisions of the decree, effective from 1 January 2016, a tax resident company of Cyprus that is the ultimate parent company of a multinational enterprise (MNE) group must submit a CbC report in its country of residency if the annual consolidated revenue of the MNE group is equal or exceeds a threshold of €750 million.

A Cyprus tax resident company that may not be the ultimate parent company of the MNE group may be considered to be the “surrogate parent company” for CbC reporting purposes if any of the following conditions is satisfied:

  • The ultimate parent company is not resident of Cyprus.
  • The ultimate parent company is not required to file a CbC report in its country of residency.
  • The country of tax residency of the ultimate parent company does not have an effective automatic exchange of information instrument with Cyprus in relation to CbC reporting, or
  • The country of tax residency of the ultimate parent company has been reported for systematic failure on exchanging information.

A surrogate parent company has the responsibility to submit the CbC report of the MNE group in place of its ultimate parent company.  

Notification and timing of reporting

Any constituent company of an MNE group that is a tax resident of Cyprus, must  notify the tax authorities of Cyprus as to whether it is the ultimate parent company (or the surrogate parent company) no later than the last day of the reporting fiscal year of the MNE group.

The date for the first notification has been extended, and the deadline for notification is 20 October 2017.

The Cyprus ultimate parent or surrogate parent company of an MNE group then will have to proceed with an electronic submission of the relevant CbC report, filed with the Cyprus tax authorities within a period of 15 months as from the end of the reporting fiscal year.

As regards to the submission of the first CbC report relating to fiscal years beginning between the period 1 January to 31 December 2016, the due date for submission has been extended by three months.  

Content requirements of CbC report

The CbC report must include the following:

  • Aggregate information relating to the amount of revenue, profit/(loss) before income tax, the amount of income tax paid, the amount of income tax accrued, the issued share capital, accumulated retained earnings, the number of employees and tangible assets (other than cash or cash equivalents) with regard to each jurisdiction in which the MNE group operates
  • Identification of each constituent company of the MNE group, by setting out the country of tax residence and the nature of its main business activities

 

Read a January 2017 report prepared by the KPMG member firm in Cyprus

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