Introduction

On the 5th of April 2019, the House of Representatives approved the proposed legislation (the Law) implementing the provisions of the European Union Anti-Tax Avoidance Directive (ATAD or Directive). The new Law will come into force once it is published in the Official Gazette of the Republic. The provisions of the Law shall be effective as of 1 January 2019 (i.e. from the tax year 2019 onwards).

The Law introduces the below:

  • Interest limitation rules
  • CFC rules
  • General Anti-abuse rule (GAAR).

The second phase of the implementation of the Directive concerning the exit taxation provisions and the Hybrid mismatch rules will be effective as of 1 January 2020.

The first implementation of the ATAD Law impacts only Cyprus Corporate Income Tax payers and more specifically Cyprus Tax Resident Companies and Cyprus Permanent Establishments (PEs) of non-Cyprus Tax Resident Companies.

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