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Cyprus Approves Law for ATAD Interest Limitation, CFC, and GAAR Rules

10 April 2019

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Approved Changes

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Cyprus

On 5 April 2019, the Cyprus House of Representatives reportedly approved a law for the transposition of certain measures of the EU Anti-Tax Avoidance Directive (ATAD). This includes the ATAD interest deduction limitation rules, controlled foreign company (CFC) rules, and general anti-avoidance rule (GAAR). Exit tax and hybrid mismatch rules are to be transposed through separate legislation. Interest Deduction Limitation The key points of the interest deduction limitation include: The deduction of net interest expense (borrowing costs) is limited to 30% of EBITDA or a EUR 3 million safe harbor; The limitation applies at the Cyprus group level, including resident...