Latest News
"Back-to-Back" financing arrangements: Retroactively terminated as of 31/12/2021
According to Circular 1/2023 of the Commissioner of Taxation, issued on 5 January 2023, “back-to-back” financing arrangements are retroactively terminated as of 31 December 2021.
Thus, from 1 January 2022 onwards, the recognition of the after tax net taxable profit margin of 2% (i.e., the simplification measures of intra-group “back-to-back” financing transactions) will no longer be applicable.
In addition, from 1 January 2022, the intra-group “back-to-back” financing transactions together with any other related party transaction must be executed at an arm’s length basis and normal commercial terms, and Companies may be required to prepare a transfer pricing study and a local file covering these transactions.
We remain at your disposal for anything you may need.
Contact person
Stelios Ioannou
This email address is being protected from spambots. You need JavaScript enabled to view it.
+357 22 100 192
Managing Director