Upcoming Enhancement of the Transfer Pricing regime in Cyprus

Recently, there have been significant tax developments in Cyprus with respect to the growing importance of Transfer Pricing (TP). With the OECD/G20 Base Erosion and Profit Shifting Project (BEPS) action plans published in 2015, the tax and TP landscape in Cyprus has seen numerous changes in recent years with further major developments which are expected shortly.

In addition, it is important that taxpayers are aware of how the current TP environment in Cyprus has evolved and how the TP regime will be enhanced with the expected completion of the implementation of the three-tiered global standard for TP documentation requirements as recommended by BEPS Action 13.

In this article, we disucuss how the Cyprus Transfer Pricing environment is expected to be further transformed by the various initiatives being undertaken globally by the OECD/G20. We also cover key considerations on the following topics:

• The TP environment in Cyprus,
• TP audits,
• Expected new TP legislations and regulations, and 
• Changes in the international tax landscape and the impact on TP in Cyprus.