On 19 September 2018, the Cyprus Tax Department issued a notice on Country-by-Country (CbC) report local filing obligations of non-parent constituent entities. The notice provides that constituent entities of Cyprus-parented MNE groups will not have local filing obligations in their jurisdiction of tax residence provided that the CbC MCAA is activated between Cyprus and the other jurisdiction. Likewise, constituent entities in Cyprus of foreign-parented groups will not have a local filing obligation in Cyprus. However, a local filing obligation in Cyprus will apply in cases where the exchange relationship is not activated by the CbC reporting deadline for the respective...