Steps and timeline
- 11–2 weeks
Map transactions
Loans, services, IP and goods between related parties: a common owner of 25% or more of votes, shares or income.
- 22–4 weeks
Benchmark
Prices from comparable deals between independent companies, following the OECD Transfer Pricing Guidelines.
- 3yearly
Document
A Cyprus local file above the thresholds, and the Summary Information Table with every tax return.
- 4on request
Answer requests
Give the file to the Tax Department within 60 days of a request.
Documents
For the transfer pricing file
The exact list depends on your situation; we confirm it before filing.
Who does what
What you do
- Share your situation and goals
- Collect documents from home
- Agree the scope of work in writing
What we do
- Check the requirements for your case
- Prepare the documents and file the application
- Follow up until the decision
Your coordinator
- Plans the work and next steps
- Keeps one timeline for everything
- Reminds you of renewals and deadlines
Common mistakes
- Interest-free loans to shareholders or group companies without an arm's-length rate
- Skipping the Summary Information Table: it is filed with every return, even below the local-file thresholds
- Adding up thresholds wrongly: they apply per category and per tax year
- Preparing the file only after a request, when it is due within 60 days
- Treating family deals as unrelated: spouses and relatives up to the third degree are connected
What affects the cost
The price depends on your situation. We explain the scope and expected costs before work begins.
Questions
Do small groups need it?
Thresholds only exempt you from the local file (from 2026: €10m for financial deals, €5m for goods, €2.5m for services and other deals a year). Below them you still keep minimum documentation, ready within 60 days on request. Every company with related-party transactions also files the Summary Information Table with its tax return.
Who counts as a related party?
A person who holds, directly or indirectly, at least 25% of a company's votes, share capital or income, alone or with connected persons. Companies with such a common owner. And the owner's spouse and relatives up to the third degree. A director who controls at least 50% of board votes also counts (Income Tax Law, section 33).
What does it look like in numbers?
A Cyprus company lends €8m to a related company and sells it €3m of services a year. The loan is under the €10m threshold for financing, so it needs no local file, but it must still carry an arm's-length rate. The services are above €2.5m, so the company keeps a local file for them. Both appear in the Summary Information Table filed with the tax return.
What are the penalties?
€500 for not filing the Summary Information Table. The file is due within 60 days of a request. If it arrives on day 61–90 the penalty is €5,000, on day 91–120 €10,000, and after day 120 or never €20,000 (Assessment and Collection of Taxes Law, section 50Z).
If the Tax Department raises the price, is the other side adjusted?
Yes, when both parties are taxed in Cyprus: the other party gets a deduction equal to the increase (Income Tax Law, section 33(5)). When the other party is abroad, relief depends on the tax treaty with that country.
Sources
- PwC Tax Summaries: Cyprus group taxation, checked 24 October 2026
- Income Tax Law 118(I)/2002, section 33: related parties, local file thresholds, 60 days, checked 28 October 2026
- Assessment and Collection of Taxes Law 4/1978, section 50Z: transfer pricing penalties, checked 28 October 2026
Figures checked 28 October 2026. Rules change: we confirm them for your case before you act.