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Cyprus’ Tax Authority issues clarification note regarding bilateral CAA with US

09 September 2020

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Tax Alerts, National/Federal Taxation, Transfer Pricing

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United States, Cyprus

On 4 September 2020, the Cypriot Tax Department publicly announced that the bilateral Competent Authority Agreement (CAA) for the exchange of Country-by-Country (CbC) reports between Cyprus and the United States (US), which is still under negotiation, is expected to be effective for Reporting Fiscal Years (RFYs) starting on or after 1 January 2020.Consequently, the secondary filing mechanism for a Cypriot Constituent Entity (CE) of a multinational enterprise group with a US tax resident Ultimate Parent Entity (UPE) is triggered for RFYs starting on or after 1 January 2019, but before 1 January 2020.Accordingly, a Cypriot CE whose UPE is a tax resident in...