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

16 October 2023

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Tax Alerts, Information Reporting, Infor...

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United States, Cyprus

The bilateral Competent Authority Agreement for the exchange of Country-by-Country reports between Cyprus and the US, which is still under negotiation, is expected to be effective for reporting financial years (RFYs) beginning on or after 1 January 2023.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 2022.Cypriot CEs that have already filed notifications in Cyprus for RFYs that began during 2022 must revise those notifications by the end of 2023 to avoid penalties.Executive summaryThe Cypriot Tax Department has publicly...