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Cyprus Tax Authority issues clarification regarding Competent Authority Agreement with the United States for exchange of CbC reports

12 October 2021

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Tax Alerts, National/Federal Taxation, T...

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United States, Cyprus

On 7 October 2021, the Cypriot Tax Department publicly announced that the bilateral Competent Authority Agreement (CAA) for the exchange of Country-by-Country (CbC) reports between Cyprus and the United States (US), which is still under negotiation, is expected to be effective for Reporting Fiscal Years (RFYs) starting on or after 1 January 2021.Therefore, the secondary filing mechanism for a Cypriot Constituent Entity (CE) of a multinational enterprise group with a US tax resident Ultimate Parent Entity (UPE) will be triggered for RFYs starting on or after 1 January 2020, but before 1 January 2021.Accordingly, a Cypriot CE whose UPE is...