On 21 July 2017, the Cyprus Ministry of Finance announced the issuance of Circular 3 of 30 June 2017, which provides new guidance/requirements on transfer pricing for intra-group financing arrangements, and in particular, intra-group back-to-back financing arrangements. The Circular follows an instruction to the Institute of Certified Public Accountants of Cyprus (ICPAC) in March 2017 that from 1 July 2017, minimum profit margins will no longer be accepted and all intra-group financing arrangements will require a transfer pricing study in accordance with OECD guidelines. According to the announcement, the Circular: Applies to any company carrying out group financing transactions that...