T&L D-briefs - September 2026
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:
- outline the release of the OECD’s 2026 report
- note the publication of comments on revisions to the OECD’s model reporting rules for digital platforms
- highlight the extension of the TD7 submission deadline
- inform you of the withdrawal of the Cyprus Tax Department’s 2017 ASP FATCA/CRS guidance
- share the recent announcement of the Registrar of Companies and Intellectual Property regarding the submission of outstanding annual returns and financial statements and the annual beneficial ownership confirmation
- outline the tax obligations applicable to Cypriot companies that form part of large multinational enterprise groups
International Tax Developments
OECD: 2026 report on tax policy reforms released
The OECD has released a report on tax policy reforms, which is the latest edition in a series of annual reports that provide comparative information on tax reforms across jurisdictions, track tax policy developments over time, and highlight trends in tax policy. The 2026 edition of the report focuses on tax reforms introduced or announced during the 2025 calendar year and covers 92 jurisdictions that are members of the OECD/G20Inclusive Framework on BEPS.
For more details click here.
OECD: Comments published on revisions to model reporting rules for digital platforms
The OECD has published responses received in connection with its invitation for public comments on a consultation document concerning proposed targeted amendments to the model reporting rules. The rules in question require digital platform operators to report information to tax authorities in respect of certain income realised by sellers through their platforms.
Please go through this link for more details.
Local Tax Developments
Extension of Deadline for Submitting the 2025 Annual Employer’s Declaration for withheld Taxes and Contributions (TD7)
The Tax Department informs that by decision of the Tax Commissioner, in order to further facilitate employers' compliance, the deadline for submitting the Annual Employer’s Declaration for withheld Taxes and Contributions (TD7) for the tax year 2025 is extended until 30th November 2026.
Submission of the aforementioned Declaration after 30 November 2026, is considered overdue and according to article 50A (a) of the Collection of Taxes Law No. 4/1978, as amended, it is subject to:
- In the case of an individual, a financial penalty of one hundred fifty euros (€150).
- In the case of a legal entity, whose turnover or assets exceed the amount of one million euros (€1.000.000), a financial penalty of five hundred euros (€500), and in every other case of a legal entity, a financial penalty of two hundred fifty euros (€250).
Cyprus Tax Department withdraws 2017 ASP FATCA/CRS guidance
We would like to inform you that, on 17 September 2026, the Cyprus Tax Department announced the withdrawal of its guide, “Cyprus Administrative Service Providers (ASPs) – Are They FIs under FATCA and CRS” (June 2017).
As a result, ASPs should no longer rely on the 2017 guidance when interpreting or applying their obligations under the OECD Common Reporting Standard (CRS). In addition, any references to this document in the Guidance Notes on the Automatic Exchange of Financial Account Information (May 2020) are no longer applicable. The Guidance Notes are expected to be updated to reflect the latest version of the CRS text.
ASPs are now required to assess their CRS classification by reference to paragraph 10ter of the Consolidated Text of the CRS (2025), together with the applicable Cyprus CRS legislative and regulatory framework. Paragraph 10ter clarifies that, for the purposes of the gross income test, which is used to determine whether an entity should be classified as a financial institution (FI) for CRS purposes, all remuneration for relevant activities must be taken into account, regardless of whether it is paid to the entity itself or to another entity.
In practice, this removes the “non-attribution” principle reflected in the 2017 guidance. For example, the fees for trustee/nominee services can no longer be disregarded by an entity that effectively provides these services, even if the fees are charged by a related party.
Who may be affected
Affected entities may include ASPs and their subsidiaries acting as corporate trustees, nominees or custodians, as well as law and accounting firms providing trustee or nominee services through related entities. Trusts and companies whose FATCA/ CRS classification depends on the status of their service providers may also be impacted.
Audits and administrative penalties
The Cyprus Tax Department has indicated that it may carry out audits to verify the compliance with CRS/ DAC2 obligations. Where non-compliance is identified, including incorrect or late reporting or failure to apply the required due diligence procedures, the Cyprus Tax Department may impose the administrative penalties provided for by law.
How we can help
We are available to assist with reassessing the FATCA/ CRS classification of entities and group structures, reviewing service and fee arrangements under the gross income test, and updating internal policies and procedures ahead of the next reporting cycle.
Please feel free to contact us should you wish to discuss how these developments may affect your organisation.
Christina Themistocleous
Director, Human Capital
Georgy Gukasyan Kuchkina
Manager, Business Tax
Cyprus Registrar Update: Important Announcement from the Registrar of Companies and Intellectual Property and Beneficial Ownership Confirmation Due by 31 December 2026
We would like to highlight two important announcements recently issued by the Registrar of Companies and Intellectual Property concerning compliance obligations for companies registered in Cyprus, both carrying a deadline of 31 December 2026. Whether you need to address outstanding annual returns or confirm your beneficial ownership information, prompt action isessential to avoid penalties.
We encourage you to review the full alert and take the necessary action ahead of the applicable deadlines.
Nicholas Sofocleous
Director, Business Process Solutions
Tax obligations for Cypriot companies that belong to large multinational
enterprises
The international tax landscape has been changing at an unprecedented pace over the last few years, especially for companies that belong to multinational enterprise groups with total consolidated turnover in excess of €750 million per annum (“MNE groups”). In this article, we briefly touch upon the obligations that are applicable to Cyprus companies that belong to such MNE groups.
For more details, read the full article here.
Harris Kleanthous
Director, Transfer Pricing
Stella Koustai
Director, Business Tax
Archive
The previous T&L D-briefs are available below.
Contact Us
For general queries and comments please contact us via email on cyprusTLdbriefs@deloitte.com.
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