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

20 October 2022

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Tax Alerts, National/Federal Taxation, Transfer Pricing

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United States, Cyprus

The Cypriot Tax Department has 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 2022..Accordingly, a Cypriot Constituent Entity (CE) whose Ultimate Parent Entity (UPE) is a US tax resident, will have an obligation to proceed with the filing of the CbC report locally in Cyprus for its RFY ending on 31 December 2021, even if a CbC report has been or will be submitted...