Friday, September 28, 2018
The Cyprus Tax Department has released a notice on the obligation on Cypriot constituent entities of multinational groups to file a CbC report in Cyprus where the ultimate parent entity files in a territory without an exchange of information arrangement with Cyprus.
The Department noted that providing a report has been filed in a territory that is a party to the CbC Multilateral Convention on Administrative Assistance and has activated automatic information sharing with Cyprus, Cyprus-based constituent entities of multinational groups need not file a report also in Cyprus.
Groups have been advised to refer to the OECD's website for a list of activated exchange of information relationships for CbC purposes.
However, if an information exchange relationship has not been activated by the CbC reporting deadline of December 31, 2018, a domestic filing obligation will arise for Cypriot constituent entities, it said. The agency further confirmed that it does not anticipate signing a CbC report exchange agreement with the US prior to this date and therefore a domestic filing requirement also arises where a group's CbC report will be filed in the US.
The Department highlighted that this announcement may affect Cypriot entities' compliance with Cyprus's notification requirement. Groups have been advised to revise their notification by December 2018 on which entity will file a CbC report, and where, to avoid penalties.