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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 (€710,000,000 for 2024, Swiss parent's consolidated accounts (invented), to be confirmed) the group is under €750,000,000, so no Master File is required of it.
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). On 2025 revenue of €780,000,000 the group is over €750,000,000, so it reports for 2026: each Cyprus company notifies who files by 31 Dec 2026; the report is due by 31 Dec 2027.
Pinewood Street Pharma Cyprus Ltd
Local File requiredLimited-risk distributor of prescription medicines
| Category | Total | Published Threshold | Exceeds? | Statute, €750,000 | Exceeds? |
|---|---|---|---|---|---|
| Goods (1 transaction) | €8,400,000 | €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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ReviewedVerifiedConfirmedNext: Reviewed, by a team member. Choose a person under View As to sign.
Evidence still outstanding: Year-end true-up calculation for the distributor, due 9 Nov 2026 — in 2 days.
Signing is still open: say in what you looked at how the conclusion stands without it.
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Content hash0238a6d31394 · a change to it reopens every sign-offPinewood Street Finance Ltd
No Local FileGroup financing company: lending is its taxable activity
| Category | Total | Published Threshold | Exceeds? | Statute, €750,000 | Exceeds? |
|---|---|---|---|---|---|
| Financing (2 transactions, by maximum principal) | €3,400,000 | €5,000,000 | No | €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: not required on the thresholds the Tax Department publishes for 2025. Tax Dept FAQ Q52 On the statute's €750,000 alone it would be required. Under the threshold: the simplified documentation of Circular 6/2023, or its safe harbours where they fit (Tax Dept FAQ Q31).
- 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, Pinewood Street Finance 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 hash8c231b8ae101 · a change to it reopens every sign-off