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Cyprus Introducing New Transfer Pricing Rules

07 July 2022

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Approved Changes

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Cyprus

On 30 June 2022, the Cyprus House of Representatives (parliament) approved the introduction of new transfer pricing rules in line with OECD guidelines. The new rules apply from 1 January 2022. This includes the amendment of Section 33 of the Income Tax Law to provide new conditions for determining whether two parties are related (connected) for transfer pricing purposes, which generally includes cases where one party directly or indirectly holds at least 25% of the voting rights, share capital, or rights to profit in another party. Two parties are also related if another party, together with connected parties, directly or...