Cyprus tax-resident companies and Cyprus permanent establishments engaging in controlled transactions with related parties above the materiality thresholds must document them. The 2026 framework sets the thresholds at €5M aggregate for financing transactions and €1M aggregate for other categories of intercompany transactions per category. Below those thresholds the simplified Summary Information Table (SIT) still applies.
Full Local File covering Cyprus entity overview, controlled-transaction analysis, functional analysis, economic analysis with benchmarking.
Drafted or reviewed: services agreements, financing facilities, royalty/licence agreements, cost-sharing arrangements — with the right transfer-pricing…
Database studies (services, financing, royalties) documented to OECD Transfer Pricing Guidelines. Comparable set, statistical range, conclusion.
Annual SIT preparation and review for entities below the Local File thresholds. Filed with the corporate income tax return.
The 2026 thresholds that decide whether you file a full Local File or the simplified SIT.
Cyprus financing entity (intercompany loans)
Cyprus IP holding entity licensing to operating companies
Cyprus management entity charging service / royalty fees
Group with multi-jurisdiction supply chain through Cyprus
Cyprus distribution arm of an international group
Pillar Two in-scope group (consolidated revenue ≥ €750M)
The engagement identifies the applicable Cyprus transfer-pricing requirements, methodology, comparables, assumptions and responsible provider. Tax-authority acceptance cannot be guaranteed.
General information. See our editorial standards and disclaimer.
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