On 29 October 2021, the tax department of Cyprus published the Decree KDP 438/2021 for the implementation of the EU directives on reportable cross-border arrangements (DAC6). The decree provides guidance on the participants in a reportable arrangement, the intermediaries, the application of the main benefit test, and the hallmarks.
Note that DAC6 reporting requirements in Cyprus have been in effect since 1 January 2021, including for historical agreements, but due to delays in implementing the required changes and enacting the regulations, administrative penalties have been eased for DAC6 reporting. The most recent relief is for the overdue submission of DAC6 information by 30 November 2021.
