T&L D-briefs - January 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 share:
The latest local and international tax developments. We would like to draw your attention to the key tax changes, effective from 1 January 2026.
Tax Developments
Local Tax Developments
Tax reform bills voted into law
Late last year, the cypriot parliament voted into law, changes into tax laws. The final legislation is the result of a long public consultation process. The key changes as per the final tax bills voted into law are summarised here and the first thoughts of our T&L Leader shared here.
International Tax Developments
Commission publishes second evaluation of administrative cooperation directives.
On 19 November 2025, the European Commission (“the Commission”) published the second evaluation of Council Directive 2011/16/EU on administrative cooperation in taxation (generally referred to as “DAC”), providing an assessment of the directive’s operation for the period 2018 - 2023. The evaluation details outcomes for each DAC module as follows:
- DAC 1: automatic exchange of information on income from employment, pensions, directors’ fees, life insurance products, and ownership of and income from immovable property
- DAC 2: automatic exchange of financial accounts information
- DAC 3: automatic exchange of information on advance cross-border tax rulings and advance pricing arrangements
- DAC 4: automatic exchange of CbC reports
- DAC 5: ensuring tax authorities have access to beneficial ownership information collected under anti-money laundering legislation
- DAC 6: potentially tax-harmful cross-border arrangements
- DAC 7: reporting rules for digital platforms
- DAC 8: tax transparency for crypto assets
- DAC 9: cooperation and information exchange in the area of minimum effective corporate taxation
For more details click here. Looking ahead, the Commission is preparing a DAC recast scheduled for the second quarter of 2026, which will encapsulate these evaluation findings and ongoing simplification objectives. This recast will aim to resolve legal fragmentation, enhance digital capabilities, harmonize penalties, and ensure the directive remains fit for purpose amid global tax developments and the expansion of the digital economy.
Tax Treaty signed with Vietnam
Following negotiations Cyprus and Vietnam have concluded a tax treaty for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income.
Key details are summarised here.
Automatic Exchange of Information on Immovable Property
On 4 December 2025 joint statement by 26 jurisdictions was made expressing their commitment to join the Multilateral Competent Authority Agreement on Automatic Exchange of Readily Available Information on Immovable Property (IPI MCAA) between tax authorities by 2029 or 2030. The key features of this mechanism are highlighted in the October 2025 OECD Report to G20 Finance Ministers and Central Bank Governors. OECD welcomed the pledge in its announcement. The above-mentioned 26 jurisdictions include Belgium, Brazil, Chile, Costa Rica, Finland, France, Germany, Gibraltar, Greece, Iceland, Indonesia, Ireland, Italy, Korea, Lithuania, Malta, New Zealand, Norway, Peru, Portugal, Romania, Slovenia, South Africa, Spain, Sweden, and the UK.
Click here for an overview of these changes and other related developments.
Cyprus – OECD Side-by-Side Package and Cyprus MoF’s Consent
On 5 January 2026, the OECD released its “Side-by-Side Package”, which includes agreed administrative guidance on a permanent simplified effective tax rate (ETR) safe harbour, an extension of the transitional Country-by-Country (CbC) reporting safe harbour, a substance-based tax incentive (SBTI) safe harbour, and a side-by-side system. See Deloitte | tax@hand for further details of the release.
Following these new OECD developments, on 8 January 2026, the Cyprus Ministry of Finance issued a press release confirming that, pursuant to Article 32 of Council Directive (EU) 2022/2523, Cyprus provides its full assurance and consent to the OECD/G20 Inclusive Framework on BEPS Side-by-Side Package approved on 5 January 2026. This statement supplements earlier announcements issued on 22 March 2023, 23 October 2023 and 24 July 2024.
Click here to access the official press release.
Archive
The previous T&L D-briefs are available below.
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