In brief

On 27 July 2020, the Cyprus Tax Authority (CTA) announced Cyprus' choosing of the option for deferral of DAC6 filing deadlines. DAC6 is an EU Directive that relates to mandatory automatic exchange of information in the field of taxation in relation to reportable cross-border arrangements. EU Member States were given the option to choose deferral of the DAC6 filing deadlines in the recent Council Directive (EU) 2020/876 of 24 June 2020 amending Directive 2011/16/EU (commonly referred to as the DAC) to address the urgent need to defer certain time limits for the filing and exchange of information in the field of taxation because of the COVID-19 pandemic.

In detail

DAC6 filing deadlines in Cyprus as per the CTA announcement

Based on the CTA announcement the Cyprus DAC6 filing deadlines are indicated to be the following:

  • for reportable cross-border arrangements (RCBAs) the first step of which was implemented between 25 June 2018 and 30 June 2020 the filing deadline is by 28 February 2021;
  • for RCBAs where the triggering event for the reporting takes place between 1 July 2020 and 31 December 2020, the filing deadline is by 30 January 2021;
  • for RCBAs where the triggering event for the reporting takes place as from 1 January 2021, the period of 30 days for filing information shall begin on the date of the triggering event;
  • for marketable RCBAs the first periodic report shall be filed by the intermediary by 30 April 2021

We note that currently Cyprus has not yet transposed the DAC6 into local law. We expect such transposition to take place in September 2020 or soon thereafter, once Parliament opens after its summer recess, in advance of the above mentioned filing deadlines.

The CTA announcement also noted that further guidance on the implementation of DAC6 and how filing will take place will be communicated by them in the future.

We note that local implementation of DAC6 in other EU Member States may differ from the above.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.