The Cyprus Tax Department announced that the bilateral CAA for exchanging CbC reports with the US is expected to apply to reporting fiscal years beginning on or after 1 January 2025, along with related local filing requirements.
The Cyprus Tax Department has issued a notice, on 25 November 2025, regarding the anticipated effective date of the agreement for the exchange of Country-by-Country (CbC) reports with the US and the related local filing requirements.
The Tax Department has informed all legal entities and their representatives that the bilateral Competent Authority Agreement (CAA) for the exchange of CbC Reports between Cyprus and the US, which is currently under negotiation, is expected to be effective for Reporting Fiscal Years starting on or after 1 January 2025.
Consequently, in the case where the Ultimate Parent Entity of a Multinational Group of Enterprises (MNE) is tax resident in the US, the secondary filing mechanism should be triggered for Reporting Fiscal Years starting on or after 1 January 2024 and before 1 January 2025.
For example, a local filing obligation should still arise in Cyprus in respect of an MNE Group’s CbC report for the Reporting Fiscal Year ending on 31 December 2024, even if a CbC Report has or will be submitted in the US.
Additionally, in the cases where notifications for reporting fiscal years starting on or after 1 January 2024 and before 1 January 2025 have been filed in Cyprus by Cypriot Constituent Entities of MNE Groups that are affected by this announcement, such notifications must be revised (if required) in accordance with this announcement. If such notifications are revised by 31 December 2025, no penalties will be imposed for the Reporting Fiscal Year starting on or after 1 January 2024 and before 1 January 2025.
