Tuesday, 1 August 2017

Cyprus' MOF revises CbC reporting decree

On 26 May 2017, the Cyprus Minister of Finance issued a revised decree on country-by-country (CbC) reporting, which replaces the decree issued on 30 December 2016. The main changes made by the new decree are as follows:

  • The obligation of a Cyprus tax resident constituent entity of a multinational (MNE) group that is not the ultimate parent entity (UPE) or the surrogate parent entity (SPE) to file a CbC report with the Cyprus tax authorities under the “secondary mechanism,” along with the corresponding notification obligation, will apply beginning with fiscal (accounting) years (FYs) starting on or after 1 January 2017.
  • The concept of an “equivalent CbC report” is introduced to require a Cyprus tax resident constituent entity of an MNE group to file a partial CbC report under the secondary mechanism in cases where the UPE has refused to provide all information necessary for the Cyprus entity to file a complete report. Since the equivalent CbC report filing falls under the secondary mechanism, it also applies with respect to FYs beginning on or after 1 January 2017.
  • A requirement to maintain books and records supporting the information disclosed in the CbC report is introduced.

The revised decree, together with the Multilateral Competent Authority Agreement on the Exchange of CbC Reports signed by Cyprus on 1 November 2016, establishes the legislative framework for the Cypriot tax authorities to collect and exchange information on MNE groups with a total consolidated group revenue of EUR 750 million or more.

Source & more info: Deloitte