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New reporting requirement for related-party financing transactions
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From tax year 2026, certain Cyprus taxpayers will be required to submit a new Financial Transactions Table to the Tax Department, in addition to their existing transfer-pricing reporting obligations.
Who is affected?
The new table applies to taxpayers whose aggregate controlled financing transactions exceed—or would exceed on an arm’s-length basis—the financing-category threshold of €10 million, triggering the requirement to prepare a Cyprus Local File for that category. A Local File obligation for another category, such as trading or services, does not by itself trigger this additional financing disclosure.
The threshold is assessed across the relevant financing transactions, not separately for each loan. Once the taxpayer is within scope, covered transactions must be reported irrespective of their individual amount.
What transactions are covered?
The table covers related-party loans and other receivable or payable balances of a financing nature where their arm’s-length remuneration is determined through an interest rate. Explicit guarantees and cash-pooling arrangements are excluded from this particular table, although other transfer-pricing obligations may still apply.
Interest-free shareholder loans
For tax year 2026, qualifying interest-free shareholder loans payable by the company are excluded from the financing threshold calculation and Summary Information Table reporting under the extended FAQ 25 transitional treatment. The arrangement must genuinely qualify for this relief, and its terms should be documented. The exclusion should not automatically be applied to interest-free loans receivable or assumed to continue beyond 2026.
Submission and review
The new table must:
- Be prepared using the Tax Department’s prescribed Excel template.
- Undergo quality assurance before submission by a person holding an ICPAC practising certificate.
- Be submitted through Tax For All as an attachment when filing the Summary Information Table.
What clients should do
To enable our firm to assess whether the new requirement applies, please provide:
- Details of all related-party loans and financing balances.
- Loan agreements and any amendments.
- Confirmation of interest-free shareholder funding.
- Balance movements and unpaid-interest information for the year.
- Details of related-party trade balances outstanding for extended periods.
Relevant Files
Companies below the financing threshold may still have other transfer-pricing documentation and reporting obligations.
Disclaimer: This circular provides general information based on the guidance reviewed as at 15 October 2026. Each company’s position should be assessed separately before filing.
