The Double Tax Treaty (DTT) of 2018 (which came in to effect on 18 July 2018, and replaced the DTT of 1974) was amended with a protocol signed on 19 December 2018
Please be informed that on 18 December 2018 the Cyprus Tax Department announced that the submission deadline for Country-by-Country (“CbC”) Reports for the 2017 Reporting Fiscal Year has been extended to 31 Jan 2019
The Cyprus Tax Department has announced that their TAXISnet system at https://taxisnet.mof.gov.cy has now been enabled to allow you to make (if needed), changes/corrections to your income Tax Returns that have already been submitted for the tax year 2017.
By activating this new feature "CHANGE TO TEMPORARY" you may change/correct your Tax Return and submit it again until November 30th 2018 without a €100,00 fine.
This is a kind reminder regarding the second and final instalment of the temporary tax return for the year ended 31 December 2018.
On 19 September 2018, the Cypriot Tax Department issued an announcement clarifying that Constituent entities with a Cypriot Ultimate Parent Entity (UPE) will not be subject to local filing in their jurisdiction of tax residency, given the relevant CbC Multilateral Competent Authority Agreement (MCAA) is activated between Cyprus and the other jurisdiction.
The Russian Ministry of Finance provides guidance on the dual tax residency status of individual tax payers.
The amended articles provide that the deadline for the submission of the personal income tax returns (T.D1s) for employees as well as for self-employees (who do note prepare audited financial statements) and the final tax payment for 2017 has been extended until 31 October 2018.
May 18th 2018: A Convention for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income was signed between the Republic of Cyprus and the Principality of Andorra.
“Substance” is a well-known tax concept used in cross-border tax structuring. The term “substance” does not appear in the actual text of double tax treaties (DTTs).
The Russian courts issued a decision on 6 March 2018 (case OJSC SUEK-Kuzbass) on the application of the Double Tax Treaty between Cyprus and Russia of 1998 as amended in 2010 (the ‘DTT’). Based on the decision interest expense was considered as non-tax deductible in accordance with the Russian thin capitalization rules.