T&L D-briefs - September 2025
T&L D-briefs is a bi-monthly tax and legal update, through articles, videos and other sources, all bundled together in a newsletter.
In this issue, we share:
- recent international case law developments
- local developments in relation to the responsibilities of employer companies
- important announcements from the Registrar of Companies.
Tax Developments
International Tax Developments
Court favors legalistic interpretation of beneficial ownership in the implementation of the EU Interest and Royalties Directive
On 12 August 2025, the Court of First Instance of Brussels (“the court”) rendered a milestone judgment in favor of the taxpayer, ruling that the beneficiary requirement in Belgium’s domestic implementation of the withholding tax exemption in the EU interest and royalties directive (IRD) should be interpreted in a legalistic manner, and not in an economic manner as endorsed by the Court of Justice of the European Union (CJEU).
For more details click here.
CJEU rules TP adjustments charged by principal are services within scope of VAT
On September 4, 2025, the Court of Justice of the European Union (CJEU) issued a pivotal decision regarding the VAT treatment of transfer pricing adjustments in the Arcomet Towercranes case. This ruling addressed whether such adjustments, made by a principal company to an operating company, fall within the scope of VAT. The CJEU ruled that charges ensuring the operating company's profit margin is within an arm's length range are indeed subject to VAT, as they constitute remuneration for services provided.
This decision provides clarity on the VAT treatment of transfer pricing adjustments, which has typically seen varied approaches by international groups and tax authorities. This case underscores the importance of robust transfer pricing documentation, not just from a transfer pricing perspective but also to substantiate the use of services in taxable transactions.
For more details click here.
Local Tax Developments
Submission of the (Employer) Tax and Contributions Withholding Statement (TF 7) via the TaxForAll (TFA) system.
The Tax Department has announced that, starting from Friday, 22/08/2025, with the reopening of the TFA system, the submission of Declaration TD7 and the payment of withholding taxes and contributions (PAYE) will be made exclusively through the TFA system.
Annual Declaration TD7 for the year 2024
- Submission Deadline: 31/12/2025.
- A Tax Identification Number (TIN) is not required for each employee.
Monthly Declarations TD7 for the year 2025
- Submission of all monthly TD7 declarations for 2025 is required starting from January 2025, even for months that have already been paid through the Tax Portal.
- A TIN is required for each employee.
Submission Deadlines for Monthly Declarations TD7 for the year 2025:
- January- November 2025: 31/12/2025
- December 2025: 31/01/2026
Payment Deadlines (PAYE) for Monthly Withholding Taxes and Contributions TD7 for the year 2025:
- June-November 2025: 31/12/2025
- December 2025: 31/01/2026
It is noted that any interests and charges that may have been calculated without considering the above deadlines will be automatically recalculated in the TFA system, taking into account the specified extensions.
Follow the link to find out more (available only in Greek).
Access to the TFA system through the CY Login service
On 20th of August 2025, the Tax Department of Cyprus announced new guidance for taxpayers accessing the Tax For All (“TFA”) platform via the CY Login platform (formerly Ariadni portal).
More precisely, starting on 22nd of August 2025, access to the TFA platform will also be possible through the CY Login service, following the system's reopening.
For Users with an existing CY Login Account:
Use your existing CY Login username and password to access TFA
For Users without a CY Login Account:
Create an account on the CY Login service to gain access
Enhanced Services Access:
- Taxpayers needing access to enhanced services requiring authentication are encouraged to log into TFA platform via CY Login.
- Accounts will be automatically linked with the Tax Identification Number (TIN) if one is held by the user
Parallel Access to TFA platform and Cy Login portals:
Users with an existing TFA account can also login via CY Login without
disruption.
Additional Resources:
A Connection Guide for accessing TFA via CY Login has been published in the "Information – Resources" section on the TAX FOR ALL support website
Business and other corporate matters
Important Announcements from the Registrar of Companies and Intellectual Property
We would like to bring to your attention two important announcements recently issued by the Registrar of Companies and Intellectual Property. These concern the annual confirmation of beneficial ownership information and the ongoing obligation to maintain accurate and up-to-date company registry data. Notably, the Registrar of Companies has highlighted a growing number of official letters being returned due to being sent to outdated registered office addresses or business premises of companies and partnerships. Such delivery failures hinder regulatory supervision and may result in legal consequences for entities that fail to comply. We encourage you to review the details carefully to ensure full compliance and avoid any potential penalties.
Please find the full information here.
Archive
The previous T&L D-briefs are available below.
You can also find more videos and news on our Youtube channel.
Contact Us
For general queries and comments on Tax Webcasts, please send an email to cyprusTLdbriefs@deloitte.com.
Subscribe to our YouTube channel to be notified when a new video is out.
