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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 (€1,120,000,000 for 2024, US parent's consolidated accounts (invented), to be confirmed) the group is over €750,000,000: its ultimate parent keeps a Master File; none of the Cyprus companies is the ultimate parent — Helios Lane Inc. (US) is, so none of them keeps one here unless one is named the Surrogate Parent Entity — to be confirmed by the practice.
Country-by-country report, for 2025: the group is over €750,000,000 for 2024, so it reports. The Ultimate Parent Entity, Helios Lane Inc. (US), files where it is resident; whether a Cyprus company must file in its place (Annex III, Section II point 1) turns on that jurisdiction's rules and agreements with Cyprus — to be confirmed by the practice. Each Cyprus company notifies who files by 31 Dec 2025 — past; whether it was made is to be established; the report is due by 31 Dec 2026 (L.205(I)/2012 s.7Γ, L.205(I)/2012 Annex III §II.3–4, L.205(I)/2012 Annex III).
Helios Lane Development Ltd
Local File requiredSoftware development centre: 140 engineers in Limassol
| Category | Total | Published Threshold | Exceeds? | Statute, €750,000 | Exceeds? |
|---|---|---|---|---|---|
| Services (1 transaction) | €10,600,000 | €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)
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Local File requiredLegal owner of the platform software; two employees, no engineers
| Category | Total | Published Threshold | Exceeds? | Statute, €750,000 | Exceeds? |
|---|---|---|---|---|---|
| Royalties and licences (1 transaction) | €3,000,000 | €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)
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Evidence still outstanding: Accounts for 2025, Helios Lane IP 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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