CYPRUS Law and Practice Contributed by: Marios Palesis and Theodora Charalambous, Kinanis LLC
15. Foreign Payment Restrictions 15.1 Restrictions on Outbound Payments Relating to Uncontrolled Transactions Cyprus does not restrict outbound payments relating to uncontrolled transactions provided they are incurred wholly and exclusively for the production of taxable income.
15.3 Effects of Other Countries’ Legal Restrictions Cyprus does not have rules regarding the effects of other countries’ legal restrictions. 16. Transparency and Confidentiality 16.1 Publication of Information on APAs or Transfer Pricing Audit Outcomes Cyprus does not publish information on APAs or TP audit outcomes. As the concept is rather new, little information is available to publish. 16.2 Use of “Secret Comparables” There is no guidance for prohibiting the use of “secret comparables” . Also, since the relevant legislation is fairly new, at this point the tax authorities do not refer to “secret comparables” .
15.2 Restrictions on Outbound Payments Relating to Controlled Transactions
Cyprus does not restrict outbound payments relating to controlled transactions, provided such payments are incurred wholly and exclu - sively for the production of taxable income and are at arm’s length.
130 CHAMBERS.COM
Powered by FlippingBook