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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.

Which threshold, for which year. For tax years 2022 to 2025 the Tax Department publishes €1,000,000 per category and €5,000,000 for financial transactions (Tax Dept FAQ Q52), above the statute's own €750,000 (ITL s.33(9)(α)). The conclusion follows the published thresholds; the statute is shown beside them. From tax year 2026 the law itself sets €2,500,000, €5,000,000 for goods and €10,000,000 for financing (L.244(I)/2025 s.17). A loan counts by its maximum principal in the year, not its interest (Tax Dept FAQ Q9–10).

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 (€238,000,000 for 2024, Group consolidated accounts (invented), to be confirmed) the group is under €750,000,000, so no Master File is required of it, Northbridge Marine 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).

Northbridge Marine Holdings Ltd

Local File required

Holding company and leader of the group's physical cash pool

CategoryTotalPublished ThresholdExceeds?Statute, €750,000Exceeds?
Financing (2 transactions, by maximum principal)€10,000,000€5,000,000Yes€750,000Yes

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)).

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Evidence still outstanding: Cash pool agreement and monthly balances, due 16 Nov 2026 — in 9 days.

Signing is still open: say in what you looked at how the conclusion stands without it.

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Northbridge Ship Management Ltd

No Local File

Technical and commercial ship management; a qualifying ship manager under tonnage tax

No controlled transactions that count in the year.

Left out of the threshold and the Summary Table:
  • Ship management of the bulk carriers, €2,400,000 — Both parties are under tonnage tax: qualifying ship management between a qualifying manager and a qualifying owner Tax Dept FAQ Q22–24

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Evidence still outstanding: Tonnage tax certificates for the manager and the owner, due 4 Nov 2026 — 3 days overdue.

Signing is still open: say in what you looked at how the conclusion stands without it.

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Northbridge Bulk Carriers Ltd

No Local File

Owns four bulk carriers; a qualifying owner under tonnage tax

No controlled transactions that count in the year.

Left out of the threshold and the Summary Table:
  • Ship management of the bulk carriers, €2,400,000 — Both parties are under tonnage tax: qualifying ship management between a qualifying manager and a qualifying owner Tax Dept FAQ Q22–24
  • Interest-free shareholder balance, €3,200,000 (principal) — An interest-free payable: left out for the company that owes it (2022–2026) Tax Dept FAQ Q25

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  • Reviewed by Niki Papas, 3 Nov 2026 14:09 · looked at: Tonnage tax status of both parties (certificates requested); interest-free balance left out for the payer (FAQ Q25). — No counted transactions: Summary Table not due, subject to the certificates.
  • Verified by Andreas Lane, 5 Nov 2026 14:10 · looked at: FAQ Q22–25 against the facts in the management accounts. — Partner to confirm the tonnage tax point.

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Northbridge Crew Services Ltd

Local File required

Crew agency for group and third-party vessels; not a qualifying ship manager, so under income tax

CategoryTotalPublished ThresholdExceeds?Statute, €750,000Exceeds?
Services (1 transaction)€1,350,000€1,000,000Yes€750,000Yes

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)).

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