As per the Cypriot Country-by-Country (CbC) reporting requirements, a CbC report must be prepared and submitted to the Tax Department by Multinational (MNEW) Groups, if the annual consolidated group revenue exceeds €750 million during the fiscal year immediately preceding the reporting fiscal year as reflected in its consolidated financial statements for such preceding fiscal year. The CbC report must be submitted either by:
The Ultimate Parent Entity (UPE) of an MNEW Group which is tax resident in Cyprus; or
The Surrogate Parent Entity (SPE) of an MNEW Group which is tax resident in Cyprus and has been appointed by the MNE Group as the reporting entity for CbC reporting purposes.
The deadline to file the CbC report with the Tax Department is 12 months from the end of the relevant accounting period, e.g. for groups with year-end 31 December 2020, the reporting deadline is by 31 December 2021.
An annual notification shall be filed to the Tax Department (through Government’s gateway portal, ARIADNI), by the last day of the fiscal year to which the CbC report relates to by the following entities:
Cypriot tax resident UPEs confirming that they are the CbC reporting entity of the Group;
Cypriot tax resident SPEs confirming that they are the CbC reporting entity for the Group and also provide the identity and tax residence of the Group’s UPE;
Cypriot tax resident Constituent Entities confirming the identity and jurisdiction of tax residence of the reporting entity of the Group.
The filing Notification for CbC reporting purposes is due by the last day of the reporting fiscal year of the Group and is done electronically via ARIADNI. The registration with ARIADNI is a one-off process and it is done for each entity separately, i.e. the entities cannot submit collectively a single notification.
Constituent entities that are tax resident in Cyprus and are neither the UPE nor the SPE of an MNE Group should consider their secondary/ local filing obligations in Cyprus for years starting on or after 1 January 2017.
For years starting on or after 1 January 2017, in cases where a UPE did not provide for whatever reason all the required information to the Constituent entity of an MNE Group for the submission of the CbC report, the Constituent entity is required to submit an Equivalent CbC report and notify the Cypriot authorities that the UPE failed to provide all the necessary available information.
Non-compliance with CbC reporting requirements may result into substantial penalties/fines.