RSM Cyprus

Implementation of the EU Anti-Tax Avoidance Directive by Cyprus

On 5 April 2019, Cyprus’ House of Representatives, voted into Law the provisions of the EU Anti-Tax Avoidance Directive. The Directive was published on 12 July 2016. The Income Tax Law has been amended on 25 April 2019, upon publication in the Official Gazette of the Republic, with the incorporation of three measures:     Interest limitation rule     Controlled Foreign Company (CFC) rule     General Anti-Abuse rule (GAAR) The three measures above will have retroactive effect as from 1 January 2019. However, the Anti-Tax Avoidance implementation measures are not limited to the above. On 24 May 2017, a second Directive was published in respect of exit taxation rules and hybrid mismatch rules. The applicable date of the two measures above is 1 January 2020. The provisions of this Directive have not yet been implemented in Cyprus Income Tax Law but is expected to be transposed into it during 2019. A brief summary of the provisions is laid in the following pages.


Please click implementation_of_the_eu_anti-tax_avoidance_directive_by_cyprus_.pdf to download the publication.

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