Transfer pricing alert

September 2022

The Cyprus Government issued the notice with the information of the master and local files along with the table of summarized information in the Official Gazette on June 30, 2022, following the approval of the transfer pricing legislation by Cyprus on that date.

The main components of the reporting files—the local file, master file, and table of summarised information—are presented in this leaflet.

Local File Content

Part I. Local Entity

• a summary of the local entity's management structure, a local organisational chart, a list of the people that local management reports to, along with the region or regions where those people have their head offices;

• a thorough explanation of the local entity's operations and business strategy;

• important competitors.

Part II. Controlled Transactions

• a summary of the controlled transactions as well as the conditions in which they occur, together with transaction amounts;

• a list of related companies engaged in controlled transactions along with their connections;

• a thorough functional and comparability analysis of the taxpayer and pertinent linked businesses with regard to each recorded controlled transaction;

• the most efficient pricing system, the factors that led to that decision, and significant assumptions that underlie the application of this transfer pricing method;

• a list as well as a summary of a few similar uncontrolled transactions, either internal or external, along with data about the search process and the source of the data;

• an explanation of the factors that led to the conclusion that pertinent transactions were valued fairly based on the use of the chosen transfer pricing model.

Part III. Financial Information

• Yearly local entity financial statements for the relevant fiscal year. Data and allocation schedules demonstrate the relationship between the annual financial reports and the financial information used to implement the transfer price strategy.

Applies To

• Cypriot tax residents; and
• Non-tax resident entities' permanent establishments.

Due Date

• must be prepared up until the local entity's deadline for filing its income tax return, and it must be updated yearly.

Master File Content

Section 1.

Group's Organizational structure

Section 2.

Details of the activities of the group

Section 3.

Intangibles if the group

Section 4.

Intercompany financial activities of the group.

Section 5.

Tax and financial positions of Group

Applies To

A multinational group's ultimate parent or surrogate parent entity with combined annual sales of EUR 750 million

Due Date

It must be prepared up until the parent entity's deadline for filing its income tax return, and it must be updated every year.

Table of Summarised Information

Below is an illustration of the information summary table. It must be created, submitted, and updated yearly up until the deadline for the local entity's income tax return.