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C. Theophilou: Cyprus experiencing a new reality in transfer pricing

Donna Kaparti     15:19 - 20 February 2024

Economy Reporter

Addressing the 7th Cyprus International Tax Conference in Nicosia, Christos A. Theophilou, International Tax & Transfer Pricing Partner, Taxand Cyprus, spoke at length about the transfer pricing challenges that define controlled transactions in terms of assets, services and expenses.

In his presentation on 20 February, he also referred to challenges in determining commercial or economic relationships and the precise delineation of the actual transaction.

Among other things, Theophilou explained that when it came to assets, an absence of rights could raise concerns about the independent nature of the transaction.

Tax authorities usually adjust pricing to reflect what would be considered appropriate under the arm's length principle, he explained.

Theophilou further commented that doing so could lead to an adjustment of taxable income and possible penalties for non-compliance.

This was followed by a series of examples regarding the challenges that arise and suggestions on how to deal with them.

(Source: InBusinessNews)

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