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15 January 2021

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Cyprus Issues Notices on DAC6 Requirements

The Cyprus Tax Department has issued two notices dated 5 January 2020 regarding the DAC6 reporting requirements for cross-border arrangements.

The first notice provides general guidance on the DAC6 reporting requirements, including the general rules for reportable cross-border arrangements, the hallmarks, etc. The guidance also includes the information to be reported, including identification of the intermediaries and taxpayers, details on why an arrangement is reportable, a summary of the arrangement, etc. Initial deadlines are also provided, which are in line with a prior notice on extended deadlines as follows:

  • Information on reportable arrangements carried out between 25 June 2018 and 30 June 2020 is due by 28 February 2021;
  • Information on reportable arrangements carried out between 1 July 2020 and 31 December 2020 is due within 30 days starting from 1 January 2021;
  • Information on reportable arrangements carried out from 1 January 2021 onwards is due within 30 days; and
  • The first periodic report on marketable arrangements is due by 30 April 2021.

When required, information on reportable cross-border arrangements is to be submitted using the Government Gateway Portal Ariadni, which involves using the online DAC6 service to upload an XML file. Further information on using the service is provided at the following link.

The second notice concerns registration specifically, including that intermediaries and taxpayers may now register for DAC6 reporting via the Ariadni portal. Once registered, required XML files may be submitted. It is further noted that because the directive for DAC6 has not yet been transposed into Cyprus domestic law the submission of DAC6 information will be voluntary until the required legislation is adopted and the requirements become mandatory. According to the first notice, the required legislation is expected to be adopted before the end of January 2021 (i.e., before the first deadline).

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