The Cyprus tax authority (CTA) opened on 14 November 2017 a public consultation on Cyprus’ transposition into national law of the two EU Directives on anti-tax avoidance (ATAD1 & ATAD2).
The CTA has published, in the Greek language, the wording of an initial draft bill (the Consultation Document) and seeks comments and suggestions in order to assist in the finalisation of the bill.
Based on ATAD1&2 all EU Member States must implement minimum standard measures for corporate taxpayers in respect of: (i) interest expenses, (ii) exit taxation, (iii) controlled foreign companies (CFCs), (iv) hybrid mismatches, and (v) a general anti-abuse rule (GAAR).
Within the minimum standards there are choices that EU Member States need to make based on the available options contained in the ATADs. The Consultation Document reflects Cyprus’ initial draft choices, but as this is Cyprus’ first step in implementing the ATADs we note that any formal legislative proposal may deviate substantially from the draft in the Consultation Document. It is anticipated that final legislative proposals and voting by the Cyprus Parliament will take place mid-2018.
Further details may be found in the PWC newsletter PWC N-15-2017.