On 5 January 2023 the Cyprus Tax department (CTD) issued a circular (1/2023) which terminates the application of “safe harbours” on back-to-back financing transactions with related parties. The termination applies from 1 January 2022 onwards. The “safe harbours” being either an after-tax return of 2% on loans granted to related parties (for pure intermediary financing companies) or a 10% after tax return on equity (for […]
