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Cyprus Circular on Transfer Pricing Method for Back-to-Back Loans

|Approved Changes|Cyprus
Cyprus

The Cyprus Tax Department has published Circular 7/2023 on transfer pricing for intra-group back-to-back financing transactions (loans). The Circular provides that from tax year 2023 (1 January 2023), the comparable uncontrolled price (CUP) method will be considered the appropriate method in documenting the arm's length price for back-to-back financing transactions as per the OECD Transfer Pri…

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