Reminder of the CbC Reporting obligations' deadlines
We would like to remind you that the following Cyprus Country-by-Country ("CbC") Reporting responsibilities have a submission date of December 31, 2022:
submission of CbC Reports for the Reporting Fiscal Year 2021 (in respect of MNE groups which have a year end of 31 December 2021*).
Submission of CbC Notifications for the Reporting Fiscal Year 2022 (in respect of MNE groups which have a year end of 31 December 2022**).
Who fall under the CbC requirements?
Large multinational enterprise ("MNE") groupings with annual consolidated group revenue of €750 million or more in the prior fiscal year are subject to CbC Reporting.
Such MNE groupings' Cypriot Constituent Entities, as specified by the law, are required to file CbC Notifications in Cyprus.
Additionally, certain Cypriot Constituent Entities are required to submit a CbC Report in Cyprus (e.g. in case they are the Ultimate Parent Entity, are appointed as a Surrogate Parent Entity or where a local secondary filing obligation arises).
What procedure must the CbC report and notifications follow?
Reports and notifications for CbC are submitted via the Ariadni Government website. For CbC reasons, each Constituent Entity of an MNE group that files a filing must be registered with this portal.
What are the consequences of not complying?
A Cypriot Constituent Entity may be fined up to €10.000 and €5.000, respectively, for failing to comply with the CbC Report and notification requirements. Each penalty may be enhanced up to €20.000 in certain instances.
How can we assist?
Taxpayers who fall under the purview of the aforementioned regulations are urged to take immediate action in order to guarantee that they fulfil their CbC Reporting requirements on schedule.
Should you need any assistance, our expert team is here to advise and assist you to meet the aforementioned requirements.
*Different deadlines apply if the accounting year end is not December 31.
**The emergence of a local secondary filing need should be examined case by case and will rely on a number of variables, including, among others, the UPE or SPE's jurisdiction of domicile and the existence of an activated exchange connection between that jurisdiction and Cyprus.
It is important to keep in mind that the bilateral CbCR exchange agreement between Cyprus and the USA is still being negotiated, which has implications for MNE Groups where the UPE is based in the USA as of the date of this Alert. The local secondary filing system for CbC Reports will be activated for the Reporting Fiscal Year ending 31 December 2021, if no agreement is negotiated and in place by the end of 2022. The Cyprus Tax Department may, like in past years, make a notification in the upcoming weeks to confirm this situation.
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Please get in contact with our Head of Business Development:
Mrs Daniella May / Head of Business Development
Tel.: + 357 7000 2 5555 / + 357 22 87 57 55
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