Cyprus calls for notification from MNEs with regards to Country-by-Country reporting

On December 30, 2016, the Ministry of Finance in Cyprus published a Decree regarding country-by-country reporting for multinational enterprises.

Country-by-Country Reporting

The Decree is consistent with EU legislation, imposing an implementation of country-by-country Reporting by all the EU Member States in conformity with the recommendations set out by the Organization for Economic Co-operation and Development (OECD) with regards to BEPS Action 13 on country-by-country reporting.

All entities of MNEs based in Cyprus with a consolidated revenue of €750 million and above are required to lay out their CbCR and provide it to the national tax authorities.


Among the Decree’s stipulations, the Ministry mentions that the guidance will require a notification by the resident constituent entities of MNE groups to the Cyprus tax authorities; this should specify the status of the MNE, whether it is the Ultimate Parent Entity or a Surrogate Parent Entity.

The Ministry states that the notification should come no later than the last day of the Reporting Fiscal Year of the enterprise. Consequently, the first notification shall take place on October 20, 2017.

In early 2017, an amendment to the penalty system on failure to comply with the CbCR requirements will be issued.

Sources: MNE Tax


Transfer Pricing Associates introduces TPA BEPS Desk. If you have any questions, or need more detailed advice on any aspects of BEPS related issues, please get in touch with us. The TPA Global network has alliance partners throughout the world, and the network can provide multi-disciplinary approach on today's critical transfer pricing challenges faced by multinational enterprises.

Copyright © 2018
Transfer Pricing Associates BV.
All rights reserved.

H.J.E. Wenckebachweg 210
1096 AS Amsterdam
T: +31 20 462 3530