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Cyprus Circular on Minimum Transfer Pricing Documentation and Simplification Measures

12 July 2023

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Approved Changes

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Cyprus

On 6 July 2023, the Cyprus Tax Department published Circular 6/2023 on minimum transfer pricing documentation and simplification measures (safe harbors) for taxpayers not required to prepare a Local file. In general, cumulative controlled transactions not exceeding EUR 750,000 per category per year are not required to be included in the Local file as per Article 33(9)(a) of the income tax law. In this respect, the Circular clarifies that when a category of controlled transactions is not required to be included in the Local file, minimum documentation is still required, including: Brief description of the functional analysis (functions, assets, risks);...