Important Update: Changes in Cyprus Controlled Transaction Transfer Pricing Documentation Requirements

There have been recent developments in the obligation to maintain a Cyprus Controlled Transaction Transfer Pricing Documentation File, which may impact your business.

According to the legislation and regulations, there is a mandatory requirement for Cypriot businesses engaged in controlled transactions during the fiscal year to maintain a Cyprus Transfer Pricing Documentation File. This obligation comes into effect if, cumulatively or by category, their controlled transactions surpass or are expected to surpass €750,000 per fiscal year, based on the arm’s length principle.

In a recent decision from the tax department, and pending the finalization of legislative regulations for the tax year 2022, the threshold for maintaining the Cyprus Transfer Pricing Documentation File has been adjusted as follows:

  • €5,000,000 for controlled transactions falling under the category of “Financial Transactions”
  • €1,000,000 for all other categories of controlled transactions.

Your business must stay compliant with these new thresholds to avoid any potential legal implications. Ensuring accurate and up-to-date documentation will not only contribute to regulatory compliance but also demonstrate your commitment to transparent and ethical business practices.

For a comprehensive understanding of this matter, you can refer to our previous publications on transfer pricing. Please click below to access relevant publications.

Examining Transfer Pricing Guidelines: The Cyprus Scenario

Simplification measures that exempt the obligation to maintain a Cyprus local file for controlled transactions for transfer pricing purposes

Cyprus transfer pricing and Cyprus taxation on intra-group transactions

Cyprus transfer pricing documentation frequently asked questions issued by the Cyprus Tax Department


Need assistance?

If you have any questions or concerns regarding these changes or need assistance in implementing the updated requirements, please feel free to contact us. We are here to support you through this transition.


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The authors expressly disclaim all and any liability and responsibility to any person, entity, or corporation who acts or fails to act as a consequence of any reliance upon the whole or any part of the contents of this publication.

Accordingly, no person, entity, or corporation should act or rely upon any matter or information as contained or implied within this publication without first obtaining advice from an appropriately qualified professional person or firm of advisors, and ensuring that such advice specifically relates to their particular circumstances.