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Cyprus tax authorities issue clarification note regarding Bilateral Agreement with the United States

04 December 2024

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

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United States, Cyprus

Cyprus tax officials have announced that the bilateral Competent Authority Agreement for the exchange of Country-by-Country reports with the United States, which is still under negotiation, is expected to be effective for reporting financial years (RFYs) beginning on or after 1 January 2024.A secondary filing mechanism for a Cypriot Constituent Entity (CE) of a multinational enterprise group with a US-tax- resident Ultimate Parent Entity applies for RFYs beginning during calendar year 2023.Cypriot CEs that have already filed notifications in Cyprus for RFYs that began during 2023 must revise those notifications by the end of 2024 to avoid penalties. Executive summaryThe Cypriot...