The Cyprus Tax Department has published Circular 7/2023 on transfer pricing for intra-group back-to-back financing transactions (loans). The Circular provides that from tax year 2023 (1 January 2023), the comparable uncontrolled price (CUP) method will be considered the appropriate method in documenting the arm's length price for back-to-back financing transactions as per the OECD Transfer Pricing Guidelines. For this purpose, reference is made to Section C.1.2.1 of Chapter X of the OECD Guidelines. The Circular further emphasizes that the use of any other method is only allowed in exceptional cases and is subject to prior approval from the Tax Commissioner...