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Obligations
What each Cyprus entity owes for financial year 2025, from its controlled transactions, each rule cited. Foreign entities are outside this practice's library and are not assessed here.
Two thresholds, and why both are shown. The law as enacted sets €750,000 per category (ITL s.33(9)(α)). A Tax Department circular of 1 February 2024 is reported to have raised it to €1,000,000, and €5,000,000 for financing (Circular 1.2.2024 · to be confirmed by the practice); the circular was not read, so those figures are to be confirmed by the practice. Rates from tax year 2026 are also reported (2026 reform, reported · to be confirmed by the practice) and no figure is used. The conclusion below follows the law as enacted.
Meridian Orchard Holdings Ltd
No Local FileHolding company and group management
No controlled transactions in the year.
- Local File: not required on the law as enacted. ITL s.33(9)(α)
- Summary Information Table: not due, filed with the income tax return; the text states no threshold. ITL s.33(10) Penalty for failing to file: €500. ACT s.50Ζ(1)
- Master File: the exemption turns on not being the Ultimate or Surrogate Parent Entity; whether this entity is one is for the practice to confirm. ITL s.33(9)(β) The revenue threshold is to be confirmed by the practice.
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Meridian Orchard Shared Services Ltd
Local File requiredFinance, IT and HR support to group companies
| Category | Total | Threshold, law | Exceeds? | Threshold, 2024 circular | Exceeds? |
|---|---|---|---|---|---|
| Services (2 transactions) | €2,760,000 | €750,000 | Yes | €1,000,000 to be confirmed by the practice | Yes |
- Local File: required on the law as enacted. ITL s.33(9)(α) Prepared by the return due date for the year (K.D.P. 273/2022 reg. 3); the due date itself is to be confirmed by the practice. Produced within 60 days of a request (ITL s.33(11)).
- Summary Information Table: due, filed with the income tax return; the text states no threshold. ITL s.33(10) Penalty for failing to file: €500. ACT s.50Ζ(1)
- Master File: the exemption turns on not being the Ultimate or Surrogate Parent Entity; whether this entity is one is for the practice to confirm. ITL s.33(9)(β) The revenue threshold is to be confirmed by the practice.
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ReviewedVerifiedConfirmed- Reviewed by Dimitri Wells, 28 Oct 2026 14:00 · looked at: Transaction totals against the trial balance (doc d-tb); the threshold rule cy.lf.threshold, Law 101(I)/2022 s.33(9)(α). — Services total agrees to the ledger.
- Verified by Marina Costa, 30 Oct 2026 14:01 · looked at: The category totals and the rule citations; the difference between the enacted threshold and the 2024 circular. — Required on either basis. Noted for the partner.
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Meridian Orchard Treasury Ltd
Local File requiredGroup financing and cash management
| Category | Total | Threshold, law | Exceeds? | Threshold, 2024 circular | Exceeds? |
|---|---|---|---|---|---|
| Financing (1 transaction) | €882,000 | €750,000 | Yes | €5,000,000 to be confirmed by the practice | No |
- Local File: required on the law as enacted. ITL s.33(9)(α) On the 2024 circular it would be not required (to be confirmed by the practice). Prepared by the return due date for the year (K.D.P. 273/2022 reg. 3); the due date itself is to be confirmed by the practice. Produced within 60 days of a request (ITL s.33(11)).
- Summary Information Table: due, filed with the income tax return; the text states no threshold. ITL s.33(10) Penalty for failing to file: €500. ACT s.50Ζ(1)
- Master File: the exemption turns on not being the Ultimate or Surrogate Parent Entity; whether this entity is one is for the practice to confirm. ITL s.33(9)(β) The revenue threshold is to be confirmed by the practice.
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ReviewedVerifiedConfirmed- Reviewed by Dimitri Wells, 28 Oct 2026 14:02 · looked at: Loan interest against the interest statements; rule cy.lf.threshold. — Financing total agrees.
- Verified by Marina Costa, 30 Oct 2026 14:03 · looked at: Threshold basis; the €5,000,000 circular figure is marked to be confirmed. — Required on the enacted threshold, not on the circular: the practice to settle which applies.
- Confirmed by Jane Doe, 1 Nov 2026 14:04 · looked at: Both threshold bases and the open point on the circular. — Proceed on the law as enacted; revisit when the circular is checked.
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Meridian Orchard Distribution Ltd
Local File requiredDistribution of juices and preserves in Cyprus and the region
| Category | Total | Threshold, law | Exceeds? | Threshold, 2024 circular | Exceeds? |
|---|---|---|---|---|---|
| Goods (1 transaction) | €6,300,000 | €750,000 | Yes | €1,000,000 to be confirmed by the practice | Yes |
| Royalties and licences (1 transaction) | €410,000 | €750,000 | No | €1,000,000 to be confirmed by the practice | No |
- Local File: required on the law as enacted. ITL s.33(9)(α) Prepared by the return due date for the year (K.D.P. 273/2022 reg. 3); the due date itself is to be confirmed by the practice. Produced within 60 days of a request (ITL s.33(11)).
- Summary Information Table: due, filed with the income tax return; the text states no threshold. ITL s.33(10) Penalty for failing to file: €500. ACT s.50Ζ(1)
- Master File: the exemption turns on not being the Ultimate or Surrogate Parent Entity; whether this entity is one is for the practice to confirm. ITL s.33(9)(β) The revenue threshold is to be confirmed by the practice.
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ReviewedVerifiedConfirmed- Reviewed by Niki Papas, 29 Oct 2026 14:05 · looked at: Goods and royalty totals; the royalty is below the threshold.
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