All taxpayers with related party transactions must electronically submit the Summary Information Table of Controlled Transactions to the tax department through the Tax For All (TFA) portal

For the tax year 2022 by 28/02/2025 and

For the tax year 2023 by 30/11/2025

Failure to submit the Summary Information Table of Controlled Transactions results in a fine of €500 for each person.

The information included in the Summary Information Table is the VAT number, the name and tax residence jurisdiction of the counterparty, the type of the controlled transaction with the corresponding amounts.

The five categories of controlled transactions are

(a)          Goods (Sale and Purchase)

(b)          Services (Provision and Receipt)

(c)           Rights and other intangible assets (Sale/Provision and Purchase/Receipt)

(d)          Financial transactions (Provision and Receipt)

(e)          Others (Sale/Provision and Purchase/Receipt)

Based on the provisions of Article 33(7) of the Income Tax Law N118(I)2002, related persons, as per Article 33(3) who

(a) are residents in the Republic or

(b) they have a permanent establishment in the Republic and are not residents in the Republic

are required to have available

(a) The Transfer Pricing Documentation File and

(b) The Summary Information Table of Controlled Transactions

according to the provisions of the Income Tax Regulations of 2022 (ΚΔΠ 314/2022), regarding their controlled transactions.

Related parties

Two companies are connected to each other if the same person (or that person and related person or group of persons with him) directly or indirectly holds 25% of the share capital or voting rights or have a right to a share of at least 25% of the income of both companies.

A company is considered to be affiliated with another person if that person (and persons affiliated with him) directly or indirectly holds 25% of the company’s share capital or voting rights, or have a right in at least 25% of the income of that company.

Two or more persons (including any other persons acting by instructions of any of them) are considered connected with each other if they act together to secure directly or indirectly 25% of the share capital or voting rights or have a right in at least 25% of the income of that company.

Obligation to maintain a Documentation File for Controlled Transaction Prices

The Documentation File for Controlled Transaction Prices consists of the Master File and the Cyprus Local File. The Documentation File must be updated every tax year.

The persons provided for in paragraph (7) of the art 33 are exempt from the obligation to maintain

(a) the Cyprus Local File provided that their transactions cumulatively do not exceed the threshold of €5 million regarding the financing category and €1 million for the other categories per tax year.

(b) the Basic file provided that the person is not the Ultimate or Surrogate Parent Entity

The Master File contains the following information (detailed description of the content is referred to in ΚΔΠ 314/2022.

(a)          The group structure

(b)          Description of the activities of the group and reference to the controlled transactions

(c)           Reference to intangible assets and controlled transactions

(d)          Reference to financing transactions and controlled financing transactions

(e)          Financial statements and Agreements

The Transfer Pricing Documentation File is made available to the Commissioner at any time upon request within 60 days from the date of notification of the relevant request by the Commissioner to the prescribed related parties. If there is a failure to make it available to the Commissioner, there are fines of €5,000, €10,000, €20,000.

The persons referred to in Article 33(7) of the Income Tax Law are required to maintain the Summary Information Table of Controlled Transactions  if controlled transactions arise within the tax year and regardless of the value of the controlled transactions.

The Summary Information Table of Controlled Transactions  is submitted only electronically through the Tax for All (TFA) Portal and for each tax year, up to the date of the obligation to submit the income declaration of the liable person for the tax year in question.

In case of non-submission of the Summary Information Table of Controlled Transactions  by the specified date, an administrative fine of €500 is imposed, as provided in Article 50Z of the Assessment and Collection of Taxes Law, as amended.