Impact of the new tax circular for intra-group financing transactions
Watch PwC Cyprus Webcast below
On 30 June 2017 the Cyprus Tax Authorities issued a circular (the Circular) providing guidance for the tax treatment of intra-group financing transactions "IGFTs". The Circular is relevant for determining taxable profits on IGFTs as from 1 July 2017 onwards and is applicable to both existing and future IGFTs. The Circular closely follows the application of the arm’s length principle of the OECD Transfer Pricing (TP) Guidelines. It requires the carrying out of a comparability analysis for the purpose of describing (delineating) IGFTs and determining the applicable arm’s length remuneration.
Understanding in detail the Circular’s requirements and their impact on existing and future transactions is important so as to facilitate adapting to these requirements as soon as possible, given their impact is as from 1 July 2017 onwards.
On 27 July, at 15:00 PwC Cyprus specialists from our international tax and transfer pricing practice provided their view on this new tax circular via a webcast.
Viewers of the webcast had and continue to have, the opportunity to submit questions via the online form to the presenters of the webcast:
Eftychios Eftychiou - Partner, Tax Reporting and Strategy, PwC Cyprus
Ioanna Stylianidou – Director, Transfer Pricing, PwC Cyprus
Director - Tax Advisory, Transfer Pricing, PwC Cyprus
Partner - Tax Reporting and Strategy, PwC Cyprus
Director - Marketing & Communications