Cyprus has introduced DAC8-driven amendments to its tax cooperation framework, effective 1 January 2026, refining reporting obligations for cross-border arrangements and clarifying the treatment of intermediaries protected by legal privilege.
The Cyprus Tax Department has announced that the Administrative Cooperation in the Field of Taxation (Amending) Law of 2026 (Law No. 38(I)/2026) entered into force on 1 January 2026, following its publication in the Official Gazette on 27 March 2026.
The amendments revise Article 7D of the principal law, which governs the automatic exchange of information on reportable cross-border arrangements. Intermediaries protected by a legally recognised lawyer–client privilege are exempt from submitting such information.
However, they must notify their client of the reporting obligation within 10 days. This notification applies either to another intermediary or, where none exists, directly to the relevant taxpayer. The term “client” broadly includes any party receiving advisory or related services tied to a reportable arrangement.
The updated provisions also clarify that exempt intermediaries must not be identified in submitted reports. Additionally, summaries of reportable arrangements must include key details such as the commonly used name (if available), a description of the arrangement, and other relevant information to help assess tax risks. Importantly, disclosures must avoid revealing trade secrets or sensitive information that could conflict with public policy.
