Country by Country Reporting – 31 December 2020 Deadline

11/09/2020

31 December 2020 is the submission deadline for the following Country-by-Country (CbC) Reporting obligations in Cyprus:

• Submission of CbC Reports for the 2019 Reporting Fiscal Year (in respect of Multinational Enterprise (MNE) groups which have a year end of 31 December 2019)

• Submission of CbC Notifications for the 2020 Reporting Fiscal Year, (in respect of MNE groups which have a year end of 31 December 2020).

For accounting years which are not the same with the calendar year different deadlines apply.

It is reminded that a Cyprus company which is a member of a reportable international group can be reported in one of the following ways:

• As an ultimate parent entity, in which case it must electronically notify the Tax Department confirming that it is the CbC reporting entity of the Group.

• As a surrogate parent entity, in which case it must electronically notify the Tax Department confirming that it is the CbC reporting entity for the Group. It must also provide the identity and tax residence of the Group’s ultimate parent entity.

• As a domestic constituent entity (“CE”), in which case it must electronically notify the Tax Department confirming the identity and tax residence of the CbC reporting entity of the Group. It must also provide the identity and tax residence of the Group’s ultimate parent entity (if different from the reporting entity).

It is also reminded that CbC Reporting applies to large MNE groups with annual consolidated group revenue of EUR750 million or more in the previous fiscal year.

On 4 September 2020 the Cyprus Tax Department announced that in respect of MNE Groups of which the ultimate parent entity is resident in the USA, the local secondary filing mechanism will be triggered for the 2019 Reporting Fiscal Year. This is because the bilateral CbC exchange agreement between Cyprus and the USA is still under negotiation.

A penalty of up to EUR10,000 in respect of Reports and EUR5,000 in respect of Notifications, may be imposed on a Cyprus company with a duty to report/notify for late filing. Under certain circumstances the penalty can increase up to EUR20,000.