Newsletter - Analysis of Tax Department Circular 6.2023 - Milimar Ltd

The Cyprus Tax Department (“CTD”) issued a Circular on 6 July 2023 (the “Circular”), with retrospective effect as of 1 January 2022, introducing Minimum TP Documentation requirements and simplification measures regarding intra-group transactions which are below the threshold of €750,000 in aggregate per category of transaction per tax year.

Furthermore, Optional Simplification Measures allowing the application of Safe Harbours have been introduced with regards to specific sub-categories of intra-group transactions, i.e., certain types of financing activity and low value-adding services, provided that adequate level of documentation is maintained.