CYPRUS Law and Practice Contributed by: Marios Palesis and Theodora Charalambous, Kinanis LLC
6. Cross-Border Information Sharing 6.1 Sharing Taxpayer Information
• other intangible assets that are non-obvious, useful and novel. Trade marks and copyrights are excluded for IP regime purposes. Qualifying persons under the IP regime include Cyprus tax residents and Cyprus tax-resident permanent establishments (PEs). 4.2 Hard-to-Value Intangibles There are no special rules regarding hard-to- value intangibles. 4.3 Cost Sharing/Cost Contribution Arrangements There are no special rules that apply to cost sharing/cost contribution arrangements. 5. Adjustments 5.1 Upward Transfer Pricing Adjustments Cyprus does not permit a taxpayer to make affirmative TP adjustments after filing tax returns unless a revised tax return is also submitted. 5.2 Secondary Transfer Pricing Adjustments While Cyprus does not have specific rules on secondary adjustments, it does provide a provi - sion within the Cyprus Income Tax Law for cor - responding adjustments, which apply specifi - cally to non-cross-border transactions between related parties.
Cyprus has signed over 60 double tax treaties and tax information exchange agreements. The Cyprus tax authorities may share information with other jurisdictions; however, fishing expe - ditions are not accepted. 6.2 Joint Audits Cyprus has a provision for joint audits in the Tax Collection and Assessments Law, which further governs the process and ensures co-operation with international tax authorities. Cyprus also actively participates in joint audits, particularly within the framework of the Euro - pean Union’s Joint Audit Programme. This pro - gramme enables tax authorities from different EU member states to collaborate on auditing multinational enterprises operating across bor - ders, ensuring consistent application of tax laws and preventing tax avoidance. Additionally, the provision of joint audits is included in the majority of the double tax trea - ties signed by Cyprus. 7. Advance Pricing Agreements (APAs) 7.1 Programmes Allowing for Rulings Regarding Transfer Pricing Cyprus has incorporated into its new TP regula - tions the opportunity for advance pricing agree - ments (APAs) to determine, in advance of con - trolled transactions, an appropriate set of criteria for the selection of pricing over a fixed period of time.
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