Cyprus announced that its upcoming CbC reporting agreement with the US will apply from 2025.
The Cyprus Tax Department, in an announcement on 25 November 2025, clarified that all legal entities and their representatives are covered by the bilateral Competent Authority Agreement for the exchange of Country-by-Country (CbC) reports between Cyprus and the US, which is currently under negotiation, is expected to apply to reporting fiscal years beginning on or after 1 January 2025.
As a result, where the ultimate parent entity of a Multinational Enterprise Group is tax resident in the US, a secondary country-by-country filing obligation arises in Cyprus for fiscal years beginning on or after 1 January 2024 and before 1 January 2025.
For example, a secondary filing obligation will apply in Cyprus for the fiscal year ending 31 December 2024, even if the CbC report has been or will be submitted in the United States.
In addition, notifications submitted in Cyprus by Cypriot constituent entities of Multinational Enterprise Groups affected by this announcement—relating to fiscal years beginning on or after 1 January 2024 and before 1 January 2025—must be amended (if required) to reflect these clarifications.
If the notifications are amended by 31 December 2025, no penalties will be imposed for the relevant fiscal years.