On 7 July 2023, the Cypriot Tax Department issued a tax circular, effective retrospectively as of 1 January 2023, providing guidance on determining arm's-length pricing for "back-to-back" financing transactions.This Alert highlights the requirements outlined in the tax circular.Executive summaryThe Cypriot Tax Department issued a circular (Circular) on 7 July 2023, with effect as of 1 January 2023, indicating that Comparable Uncontrolled Price (CUP) is the most appropriate documentation method for "back-to-back" financing transactions. Further, the Circular states that another transfer pricing method may be used only in exceptional cases and only if it is preapproved by the Cyprus Tax Commissioner...