Transfer Pricing Rules in Cyprus in 2023

Cyprus, with its strategic location and favorable tax environment, continues to attract international businesses. In 2023, it’s essential for companies operating in Cyprus to have a firm grasp of the transfer pricing rules in place. This article explores the key features of these regulations, recent changes for the year 2023, and their impact on multinational corporations.

Transfer Pricing Regulations in Cyprus

Cyprus enforces transfer pricing regulations to prevent tax evasion and ensure that transactions between related entities are conducted fairly. The arm’s length principle is at the core of these regulations, demanding that related entities set prices similar to those between unrelated entities in similar circumstances.

Key Features of Transfer Pricing Rules in Cyprus

Documentation Requirements: One of the fundamental aspects of these rules is the requirement for businesses to maintain meticulous documentation of their transfer pricing policies. This documentation is crucial for proving that transactions are conducted at arm’s length. Failure to comply can lead to penalties.

Transfer Pricing Methods: Cyprus offers businesses various methods to determine appropriate transfer prices. These methods include the comparable uncontrolled price method, cost-plus method, resale price method, and profit split method. The choice of method should align with the specific circumstances of the transactions.

Advance Pricing Agreements (APAs): Companies can seek Advance Pricing Agreements (APAs) to secure assurance from the Cyprus tax authorities regarding their transfer pricing arrangements. APAs can reduce uncertainty and potential disputes, providing a level of predictability for businesses.

Transfer Pricing Audits: The Cyprus tax authorities are responsible for conducting transfer pricing audits to ensure compliance with the regulations. These audits involve a thorough examination of a company’s transfer pricing documentation. To prepare for these audits, businesses should maintain comprehensive and accurate documentation.

Impact on Multinational Companies

Multinational companies operating in Cyprus need to pay close attention to these transfer pricing regulations. By establishing clear transfer pricing policies and maintaining accurate documentation, they can ensure compliance with the law. Moreover, adhering to these regulations helps prevent disputes with tax authorities and fosters a more transparent and efficient business environment.

Recent Changes in 2023

In 2023, businesses operating in Cyprus should be aware of any recent changes to transfer pricing rules. Legislative updates may impact how transfer pricing is managed, necessitating vigilance and adaptation to remain in compliance with the law.

The Cyprus tax authorities often seek to align the country’s transfer pricing regulations with international best practices. This alignment ensures that businesses can conduct their operations with confidence, knowing they are following transparent and globally accepted standards.

One notable change in 2023 pertains to the documentation requirements. Cyprus authorities may require even more detailed and precise documentation to demonstrate that transactions comply with the arm’s length principle. This change reflects a broader trend worldwide, where tax authorities are placing greater scrutiny on transfer pricing practices to combat tax avoidance.

Another change involves the introduction of new transfer pricing methods. Cyprus authorities may expand the list of acceptable methods or provide additional guidance on existing methods. Businesses should keep an eye on these changes to ensure that their transfer pricing methodologies align with the latest regulatory updates.


In summary, compliance with transfer pricing rules in Cyprus is essential for businesses, particularly for international companies taking advantage of Cyprus’s strategic location and tax advantages. The regulations aim to prevent tax evasion and promote fair practices in intercompany transactions. By staying informed about the rules and adapting to any changes in 2023, businesses can operate confidently in Cyprus while complying with transfer pricing regulations.

These regulations, rooted in the arm’s length principle, underpin a transparent and equitable business environment, fostering trust between businesses and tax authorities. Staying up-to-date with these rules ensures not only legal compliance but also a solid foundation for international corporations to thrive in Cyprus.

by mojodigital