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Obligations
What each Cyprus entity owes for financial year 2025 — Local File, Summary Information Table (the Summary Table, for short), Master File — from its controlled transactions, each rule cited. Foreign entities are outside this practice's library and are not assessed here.
Which documents each Cyprus entity owes, each threshold cited.
Master File, for the group: only an Ultimate or Surrogate Parent Entity keeps one (ITL s.33(9)(β)), and a group under €750,000,000 of consolidated revenue is outside it (L.205(I)/2012 Annex III). On the revenue on file (€158,000,000 for 2024, Group consolidated accounts (invented), to be confirmed) the group is under €750,000,000, so no Master File is required of it, Cobalt Bay Resorts Holdings Ltd included.
Country-by-country report: on the revenue on file the group is under €750,000,000 for 2024, so none for 2025 (L.205(I)/2012 s.7Γ, L.205(I)/2012 Annex III §II.3–4, L.205(I)/2012 Annex III).
Cobalt Bay Resorts Holdings Ltd
Local File requiredHolding company and group management
| Category | Total | Published Threshold | Exceeds? | Statute, €750,000 | Exceeds? |
|---|---|---|---|---|---|
| Services (1 transaction) | €680,000 | €1,000,000 | No | €750,000 | No |
| Financing (1 transaction, by maximum principal) | €20,000,000 to be confirmed by the practice (how a guarantee is measured against the threshold is not stated in the FAQ (question 5)) | €5,000,000 | Yes | €750,000 | Yes |
Totals are the booked figures; a category near the line is re-tested after any year-end adjustment (True-Ups), since the law tests the arm's length amount (ITL s.33(9)(α)).
- Local File: required on the thresholds the Tax Department publishes for 2025. Tax Dept FAQ Q52 It rests on a point not settled in the sources read — measuring the guarantee by the guaranteed amount — to be confirmed by the practice. Prepared, with a certified accountant's quality check, by the return due date (K.D.P. 273/2022 reg. 3): for 2025, 31 Mar 2027 (ACT, to 2025 · to be confirmed by the practice); from tax year 2026, 31 January of the second year (ACT s.5(1A)). Produced within 60 days of a request (ITL s.33(11)).
- Summary Information Table: due, filed with the income tax return, whatever the value. ITL s.33(10) Penalty for failing to file: €500. ACT s.50Ζ(1) Summary Table Lines (CSV)
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Evidence still outstanding: Bank facility letter and any guarantee fee correspondence, due 30 Oct 2026 — 8 days overdue.
Evidence still outstanding: Accounts for 2025, Cobalt Bay Resorts Holdings Ltd, due 20 Nov 2026 — in 13 days.
Signing is still open: say in what you looked at how the conclusion stands without it.
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Content hashbd51919f71fa · a change to it reopens every sign-offCobalt Bay Brands Ltd
Local File requiredOwns and licenses the Cobalt Bay hotel brand
| Category | Total | Published Threshold | Exceeds? | Statute, €750,000 | Exceeds? |
|---|---|---|---|---|---|
| Royalties and licences (1 transaction) | €1,620,000 | €1,000,000 | Yes | €750,000 | Yes |
Totals are the booked figures; a category near the line is re-tested after any year-end adjustment (True-Ups), since the law tests the arm's length amount (ITL s.33(9)(α)).
- Local File: required on the thresholds the Tax Department publishes for 2025. Tax Dept FAQ Q52 Prepared, with a certified accountant's quality check, by the return due date (K.D.P. 273/2022 reg. 3): for 2025, 31 Mar 2027 (ACT, to 2025 · to be confirmed by the practice); from tax year 2026, 31 January of the second year (ACT s.5(1A)). Produced within 60 days of a request (ITL s.33(11)).
- Summary Information Table: due, filed with the income tax return, whatever the value. ITL s.33(10) Penalty for failing to file: €500. ACT s.50Ζ(1) Summary Table Lines (CSV)
Sign-Off
ReviewedVerifiedConfirmedNext: Reviewed, by a team member. Choose a person under View As to sign.
Evidence still outstanding: Accounts for 2025, Cobalt Bay Brands Ltd, due 20 Nov 2026 — in 13 days.
Signing is still open: say in what you looked at how the conclusion stands without it.
Hash
Content hash2ee84a9907cb · a change to it reopens every sign-off