The Rules

Every threshold, margin, deadline and principle this tool uses, with its source. 20 of 28 are verified against the primary text; the rest say to be confirmed by the practice wherever they appear, and no tool figure comes from memory.

For the practice to check. “Verified” means the primary text was read on 6 November 2026 by the building session and the supporting sentence is quoted here; it is not the practice's sign-off. The Tax Department's own site could not be read automatically, so no circular or FAQ is verified. Where a figure is reported but unread, it is shown only as a comparison and is marked.

Cyprus law

Rule	What it says	Figure	Source	Status
Documentation duty and its start `cy.law`	The 2022 amendment inserted sections 33(6)–(13) and the new section 33Γ into the Income Tax Law. In force from 1 January 2022. “Η ισχύς του παρόντος Νόμου λογίζεται ότι άρχισε την 1η Ιανουαρίου 2022”	—	Income Tax (Amendment) (No. 4) Law 2022, 101(I)/2022 articles 3, 4 and 6	Verified Read 2026-11-06
The OECD Guidelines as the interpretation `cy.oecd-link`	The arm's length provisions may be applied and interpreted in accordance with the OECD Guidelines, as amended from time to time. “Οι διατάξεις του εδαφίου (1) δύναται να εφαρμόζονται και ερμηνεύονται σύμφωνα με τις Οδηγίες του [ΟΟΣΑ]… όπως αυτές εκάστοτε τροποποιούνται”	—	Income Tax (Amendment) (No. 4) Law 2022, 101(I)/2022 section 33(6)	Verified Read 2026-11-06
Connected persons `cy.related`	Persons are connected at a 25% test of voting rights, share capital or share of income, directly or indirectly, with group and acting-together variants. A controlled transaction is one between connected persons.	25.00%	Income Tax (Amendment) (No. 4) Law 2022, 101(I)/2022 section 33(3)(γ)–(ε) and section 2	Verified Read 2026-11-06
Who keeps the documentation file `cy.who`	Connected persons that are Cyprus tax resident, or non-resident with a Cyprus permanent establishment, keep a documentation file and a Summary Information Table of controlled transactions. The file is the Master File and the Cyprus Local File, as applicable.	—	Income Tax (Amendment) (No. 4) Law 2022, 101(I)/2022 section 33(7)–(8)	Verified Read 2026-11-06
Advance pricing agreements `cy.apa`	The Commissioner decides within 10 months (extendable to 24); a decision lasts at most 4 years and cannot cover past years.	10 months	Income Tax (Documentation of Controlled Transactions) Regulations, K.D.P. 273/2022 regulation 4; section 33Γ	Verified Read 2026-11-06

Local File

Rule	What it says	Figure	Source	Status
Local File threshold, as enacted `cy.lf.threshold`	No Local File where controlled transactions, in aggregate per category, do not exceed €750,000 in the tax year. "Do not exceed": exactly €750,000 is exempt. This is the figure as enacted in 2022; later changes are reported but not verified (next two rules). “αθροιστικώς, ανά κατηγορία, δεν υπερβαίνουν… τις επτακόσιες πενήντα χιλιάδες ευρώ (€750.000) ανά φορολογικό έτος”	€750,000	Income Tax (Amendment) (No. 4) Law 2022, 101(I)/2022 section 33(9)(α)	Verified Read 2026-11-06
Local File threshold raised by circular (2024) `cy.lf.threshold.circ2024`	Reported: a Tax Department circular of 1 February 2024, retrospective to tax year 2022, raised the threshold to €1,000,000 for all categories except financing, at €5,000,000 (next rule). The circular itself was not read; only secondary summaries.	€1,000,000	Tax Department circular of 1 February 2024 not read; summarised in a Cyprus Bar Association leaflet	To be confirmed by the practice
Local File threshold for financing, circular (2024) `cy.lf.threshold.circ2024.fin`	Reported: €5,000,000 for the financing category under the same circular.	€5,000,000	Tax Department circular of 1 February 2024 not read; secondary summaries only	To be confirmed by the practice
Local File thresholds from tax year 2026 `cy.lf.threshold.2026`	Reported by a professional-services alert: the December 2025 tax reform raises the thresholds from tax year 2026 (financial, goods and other categories at different levels). The enacting text was not found, and another firm's figures differ. No figure is used.	—	Secondary alert (professional-services firm, January 2026) enacting law not located; not cited by name	To be confirmed by the practice
When the Local File is prepared and kept `cy.lf.prepare`	Prepared by the income tax return due date for the tax year it covers, and accompanied by the Summary Information Table. A quality-assurance check by a certified accountant is done by that date. Kept at the premises for the books-retention period; updated annually. The return due date itself is a separate rule, below.	—	Income Tax (Documentation of Controlled Transactions) Regulations, K.D.P. 273/2022 regulation 3(1)–(3); section 33(10) proviso	Verified Read 2026-11-06
The income tax return due date `cy.return.due`	The date the file is due follows the return's due date. That date was not read from its source in this build.	—	Income Tax Law, return provisions not read	To be confirmed by the practice
Production on request `cy.lf.request`	The file is produced within 60 days of the Commissioner's notice.	60 days	Income Tax (Amendment) (No. 4) Law 2022, 101(I)/2022 section 33(11)	Verified Read 2026-11-06

Master File

Rule	What it says	Figure	Source	Status
Master File: who is exempt `cy.mf`	A person is exempt from the Master File if it is not the Ultimate or Surrogate Parent Entity as defined in the administrative cooperation law. “σε περίπτωση κατά την οποία δεν αποτελούν την Τελική Μητρική Οντότητα ή Παρένθετη Μητρική Οντότητα”	—	Income Tax (Amendment) (No. 4) Law 2022, 101(I)/2022 section 33(9)(β)	Verified Read 2026-11-06
Master File revenue threshold `cy.mf.threshold`	The consolidated-revenue threshold comes from the administrative cooperation law (DAC4), not from section 33. Not read.	—	Administrative cooperation law, 205(I)/2012 Annex III; not read	To be confirmed by the practice

Summary Information Table

Rule	What it says	Figure	Source	Status
The Summary Information Table `cy.sit`	Filed electronically for every tax year with the income tax return. The text states no monetary threshold. (The Tax Department's FAQ is reported to say it is required regardless of value; that is a secondary report. No form number is cited.) “για κάθε φορολογικό έτος μαζί με τη δήλωση εισοδήματος”	—	Income Tax (Amendment) (No. 4) Law 2022, 101(I)/2022 section 33(10)	Verified Read 2026-11-06

Penalties

Rule	What it says	Figure	Source	Status
Penalty: Summary Information Table `cy.pen.sit`	Administrative fine of €500 for failing to file the table. “διοικητικό πρόστιμο ύψους πεντακοσίων ευρώ (€500)”	€500	Assessment and Collection of Taxes (Amendment) (No. 5) Law 2022, 100(I)/2022 new section 50Ζ(1)	Verified Read 2026-11-06
Penalty: file not produced on request `cy.pen.file`	If not produced within the 60 days: €5,000 if produced on days 61–90; €10,000 on days 91–120; €20,000 if produced after day 120 or not at all.	—	Assessment and Collection of Taxes (Amendment) (No. 5) Law 2022, 100(I)/2022 section 50Ζ(2)(α)–(γ)	Verified Read 2026-11-06

Services and financing

Rule	What it says	Figure	Source	Status
Low value-adding services, Cyprus circular `cy.lvas`	Reported: Circular 6/2023, provider minimum 5% on total costs and recipient maximum 5%, only for persons exempt from the Local File. The circular was not read. No Cyprus rule is applied on this basis.	5.00%	Tax Department Circular 6/2023 not read; secondary summaries only	To be confirmed by the practice
Intra-group financing: Cyprus simplified approach `cy.fin`	Reported: a simplified approach for back-to-back financing in Circular 6/2023, with rates revised from tax year 2026 by Circular 5/2026. Neither was read, and no margin is shown. The financing item compares the interest charged with the practice's own yield analysis, entered with its source.	—	Tax Department Circulars 6/2023 and 5/2026 not read	To be confirmed by the practice

Benchmarking

Rule	What it says	Figure	Source	Status
Which quartile definition the study uses `method.quartile`	The three common definitions give different ranges on the same data, so all three are shown. The practice's house choice (and whether the Tax Department has a preference) is not in a source read here. The study defaults to the inclusive definition.	—	Practice policy to be set by the practice	To be confirmed by the practice

OECD Guidelines

Rule	What it says	Figure	Source	Status
The arm's length principle `oecd.alp`	The authoritative statement of the arm's length principle is in Article 9(1) of the OECD Model Tax Convention. “The authoritative statement of the arm's length principle is found in paragraph 1 of Article 9 of the OECD Model Tax Convention”	—	OECD Transfer Pricing Guidelines 2022 paragraph 1.6	Verified Read 2026-11-06
The five comparability factors `oecd.factors`	Contractual terms; functions, assets and risks; characteristics of property or services; economic circumstances; business strategies.	—	OECD Transfer Pricing Guidelines 2022 paragraph 1.36	Verified Read 2026-11-06
The typical comparability process `oecd.process`	A typical nine-step process, accepted good practice but not compulsory. “a typical process… considered an accepted good practice but it is not a compulsory one”	—	OECD Transfer Pricing Guidelines 2022 paragraph 3.4	Verified Read 2026-11-06
Identifying and selecting comparables `oecd.select`	Additive and deductive approaches (3.40–3.42). The process should be transparent, systematic and verifiable (3.46). “transparent, systematic and verifiable”	—	OECD Transfer Pricing Guidelines 2022 paragraphs 3.38–3.46	Verified Read 2026-11-06
Comparability adjustments `oecd.adjust`	Adjustments are to be considered only if they are expected to increase the reliability of the results. “considered if (and only if) they are expected to increase the reliability of the results”	—	OECD Transfer Pricing Guidelines 2022 paragraph 3.50	Verified Read 2026-11-06
The interquartile range `oecd.iqr`	Where comparability defects remain, statistical tools that take account of central tendency may be used to narrow the range, for example the interquartile range or other percentiles. Paragraphs 3.60–3.62 deal with the point in the range. “statistical tools that take account of central tendency to narrow the range (e.g. the interquartile range or other percentiles)”	—	OECD Transfer Pricing Guidelines 2022 paragraph 3.57 (and 3.60–3.62)	Verified Read 2026-11-06
Low value-adding services: the 5% mark-up `oecd.lvas`	The simplified approach for low value-adding intra-group services: a mark-up of 5% of the relevant cost, which does not need to be justified by a benchmarking study. Defined in 7.45. “The mark-up shall be equal to 5% of the relevant cost… does not need to be justified by a benchmarking study.”	5.00%	OECD Transfer Pricing Guidelines 2022 paragraphs 7.45 and 7.61	Verified Read 2026-11-06
Master File and Local File content `oecd.docs`	Chapter V introduces the Master File and Local File (5.18–5.23). Annex I to Chapter V sets the Master File content and Annex II the Local File content; the annexes carry no paragraph numbers.	—	OECD Transfer Pricing Guidelines 2022 Chapter V, Annex I and Annex II	Verified Read 2026-11-06