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Key Takeaway
From the 2026 tax year onwards, taxpayers falling within the scope of the relevant Cyprus transfer pricing provisions will be required to submit the Table of Financial Transactions electronically through the Tax For All (TFA) platform where their controlled financing transactions exceed, or would exceed under the arm's length principle, the applicable threshold. The Table must also undergo a quality assurance review prior to submission.
The Tax Department has published a dedicated Table for Financing Transactions together with a comprehensive Guide to facilitate the reporting of controlled financing transactions for transfer pricing purposes. The new reporting requirement applies as from the 2026 tax year and forms part of the continued development of Cyprus' transfer pricing compliance framework.
What has changed?
From the 2026 tax year onwards, the Table of Financial Transactions must be submitted electronically through the Tax For All (TFA) platform as an attachment to the Summary Information Table of Controlled Transactions by taxpayers falling within the scope of Article 33(7) of the Income Tax Law, where their controlled transactions classified as "Financing Transactions" exceed, or would exceed under the arm's length principle, the threshold provided in Article 33(9) of the law.
To support taxpayers in meeting this requirement, the Tax Department has made available:
- A template for Table of Financial Transactions in Excel format; and
- A detailed Guide containing instructions regarding the transactions that must be disclosed, together with guidance on the completion and submission of the Table.
Quality Assurance Requirement
The Table of Financial Transactions is required to undergo a quality assurance review prior to submission, in accordance with Regulation 3(3) of Decree 273/2022. Taxpayers should therefore ensure that adequate procedures are in place to facilitate compliance with this requirement before filing.
Why is this important?
The introduction of a dedicated reporting schedule for financing transactions demonstrates the increasing focus of the Cyprus transfer pricing framework on intra-group financing arrangements and the collection of standardised information by the tax authorities. The availability of both a prescribed template and accompanying completion guidance provides taxpayers with greater clarity in relation to the information expected to be reported and the manner in which such information should be presented.
Businesses with intercompany loans, cash pooling arrangements, financial guarantees and other financing transactions should assess whether they fall within the reporting thresholds and ensure that the necessary information is gathered in a timely manner in preparing for the filing process.
RSM Cyprus Comment
The publication of both the Table of Financial Transactions and its accompanying Completion Guide represents a significant practical development in Cyprus transfer pricing compliance. Taxpayers should familiarise themselves with the template and reporting instructions at an early stage, as the information requested may require coordination between tax, finance and treasury functions.
Given the increasing level of transparency expected by the Tax Department, businesses involved in material intra-group financing arrangements should consider reviewing their existing transfer pricing documentation and supporting analyses to ensure consistency between the information reported in the Table and the broader transfer pricing position adopted by the group.
What taxpayers need to know
The new reporting requirement applies from the 2026 tax year onwards.
The Table must be submitted by taxpayers falling within the scope of Article 33(7) of the Income Tax Law where their controlled transactions classified as "Financing Transactions" exceed, or would exceed under the arm's length principle, the threshold provided in Article 33(9) of the law.
The Table of Financial Transactions must be submitted electronically through the Tax For All (TFA) platform as an attachment to the Summary Information Table of Controlled Transactions.
Yes. The Table of Financial Transactions is required to undergo a quality assurance review prior to submission, in accordance with Regulation 3(3) of Decree 273/2022.
Businesses with intercompany loans, cash pooling arrangements, financial guarantees, and other financing transactions should assess whether they meet the applicable reporting thresholds.
How RSM Cyprus Can Help
RSM Cyprus can help businesses assess the new reporting requirements, review financing transactions and existing transfer pricing documentation, and prepare for the completion and quality assurance review of the Table of Financial Transactions.
Our Transfer Pricing team can also help businesses assess whether their existing documentation and supporting analyses align with the information required under the new framework.
For personal consultation, you can contact our tax team.
