The Cyprus Tax Department announced that the bilateral Competent Authority Arrangement (CAA) for the exchange of Country-by-Country (CbC Reports) between Cyprus and the United States of America, which is currently under negotiation, is expected to be effective for Reporting Fiscal Years starting on or after 1 January 2020.
Consequently, in the case where the Ultimate Parent Entity of a Multinational Group of Enterprises (MNE) is tax resident in the United States of America, the secondary filing mechanism should be triggered for Reporting Fiscal Years starting on or after 1 January 2019 and before 1 January 2020.
In the cases where notifications for reporting fiscal years starting on or after 1 January 2019 and before 1 January 2020 have been filed in Cyprus, by Cypriot Constituent Entities of MNE Groups ,which are affected by this announcement, such notifications must be revised, if required, in accordance with this announcement, which has been published by the Cyprus Tax Department on the 4th September 2020. If such notifications are revised by 31 December 2020, no penalties will be imposed for the Reporting Fiscal Year starting on or after 1 January 2019 and before 1 January 2020.
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