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Regulatory Blog

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Upcoming deadline for Country-by-Country reporting in Cyprus
The submission of the Country-by-Country reporting/notification obligations in Cyprus is due by 31 December 2022.
BVI empowers its International Tax Authority to issue administrative penalties and take other enforcement action
On 4 August 2022, BVI passed the International Tax Authority (Administrative Penalties) Regulations (the Regulations). The Regulations came into force as of 14 June 2022.
Newly voted transfer pricing legislation in Cyprus
On 30 June 2022, the Cyprus Parliament passed into law the transfer pricing (TP) rules and documentation requirements by amending the tax legislation. The OECD Transfer Pricing Guidelines have been legislatively incorporated in Cyprus.
European Commission proposes a tax incentive to reduce for debt-equity bias
On 11 May 2022, the European Commission (EC) proposed a Directive on a debt-equity bias reduction allowance (DEBRA) by introducing an allowance that will allow for a notional interest deduction on equity increases from one tax year to the next. The objective is to reduce the current tax bias that favours the use of debt over equity. The focus of the proposed measure is on the entity being funded rather than on the lender or equity provider.
OECD initiates a public consultation on tax transparency framework for crypto-assets and common reporting standard amendments regarding digital funds
On 22 March 2022, the OECD released a public consultation document concerning a new global tax transparency framework to provide for the reporting and exchange of information with respect to crypto-assets, as well as amendments to the Common Reporting Standard (CRS) for the automatic exchange of financial account information between countries.
Special levy on income relating to real estate located in Luxembourg for Luxembourg investment funds
The Finance bill for the Financial Year 2021 introduced a special levy on rental income and capital gains deriving from real estate located in Luxembourg and held directly or indirect by investment funds (art. 4 of the law dated 19 December 2020). The Luxembourg Tax Authorities recently issued a circular dated 20 January 2022 concerning the implementation, declaration, and payment of this special levy.
BVI International Tax Authority imposes annual fee for FATCA, CRS and country-by-country reporting
On 11 February 2022, BVI’s International Tax Authority announced its intention, effective 1 September 2022, to introduce an annual fee to each entity enrolled in the BVIFARS Portal who is required to report under the Common Reporting Standards, Foreign Account Tax Compliance Act, and Country-by-Country Reporting.
OECD published its updated Transfer Pricing Guidelines on Multinational Enterprises and Tax Administrators
On 20 January 2022, the Organisation for Economic Cooperation and Development (OECD) released its updated edition of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.
DAC6: Cyprus Guidance now in English
As mentioned in our previous post, the Cyprus DAC6 Guidance has been with us since October 2021, but has to date been available only in Greek (publicly at least).
Important update: DAC6 now in Cyprus
On 31 January, the Cyprus Tax Department (CTD) finally brought the regime providing for the mandatory reporting of reportable cross border arrangements (RCBAs), known as DAC6, into force in Cyprus. Up until this point, various transitional provisions and safe-harbours had been in place to soften the introduction of the regime.
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