Insights: Article

Tax Treatment of Intra-Group Financing Arrangements

Published July 12, 2017

July 28, 2017

"On 30 June 2017, the Cyprus Tax Department issued an interpretative circular relating to the revised tax treatment of intra-group financing arrangements which apply from 1 July 2017. The circular follows the application of the arm’s length principle of the OECD Transfer Pricing Guidelines.

The Cyprus Tax Department announced earlier this year that the application of the pre-agreed minimum profit margins (of 0,125% to 0,35%) for ‘back-to-back loans’ will be terminated as at 30 June 2017. The new framework laid out in the circular will apply to these and certain other financing arrangements going forward."

HLBI International analyzed the main provisions of the circular. To read more, click HERE.

Latest Insights

July 13, 2018
Article
Here are some idea for giving your new hire a smooth start into your business and alleviating stress for you.
July 13, 2018
Article
The impact of the recent SCOTUS Wayfair decision will continue to have a ripple effect on businesses and state sales tax compliance.
July 9, 2018
Article
The revenue cycle is a complex system and we have historically given much attention to the front-end and back-end while oftentimes leaving the middle functions of the cycle neglected.
July 3, 2018
Article
FASB Accounting Standards Codification Topic 606, Revenue from Contracts with Customers, provides a 5-step framework for determining revenue recognition.
July 2, 2018
Article
As part of the Tax Reform Act of 1986, the “Kiddie tax,” a taxing regime designed to make the transfer of income items by wealthy parents to lower tax paying children less attractive, was implemented.
July 2, 2018
Article
When it comes to your employees, you likely conducted interviews on them when you first hired them.
July 2, 2018
Article
Nearly ten years after the release of the initial exposure draft, FASB issued ASU 2016-02, Leases - The standard may have been issued, but the conversation about this re-write of legacy guidance has not slowed.
June 29, 2018
Article
Banks look at three broad categories when considering small business financing: business cash flow, personal financial strength, and collateral value.
June 28, 2018
Article
You need to be cautious when entering into a bartering relationship and remember to track everything and the key to accounting for bartering is making sure you still record the income earned and expenses incurred.