New Transfer Pricing Legislation in Cyprus

Marios Palesis

Cyprus introduced new transfer pricing law setting documentation requirements on intragroup transactions between related entities. The law and regulations are aligned with the OECD Transfer Pricing Guidelines and apply as from 1st of January 2022.


The major changes in the amended law are:

  1. The introduction of 25% relationship test in related parties’ definition;
  2. Introduction of the three-tiered documentation (master file/local file/summary table) subject to exemptions;
  3. Preparation of transfer pricing studies for all intragroup transactions;
  4. Introduction of penalties for non-compliance with the law;
  5. Introduction of Advanced Pricing Agreements.

For detailed information feel free to contact our office via our website.


XLNC TFG Newsflash| October 2022


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