Cy Transfer Pricing

Cyprus transfer pricing for tax year 2026: the arm's length rule in article 33 of the Income Tax Law 118(I)/2002, connected persons (the 25% test, relatives, partners, and from 2026 a director with 50% of board votes), the 2026 local file thresholds (EUR 2,500,000 per category, EUR 5,000,000 for goods, EUR 10,000,000 for financing), the master file and country-by-country report at EUR 750m, the Summary Information Table, the 60-day production rule, penalties of EUR 500 to EUR 20,000, APAs, MAP and the EU dispute procedure, the Tax Department's simplification measures and safe-harbour returns (Circulars 6/2023 and 5/2026: 5% low value-adding services mark-up, financing returns), Circular 7/2023 on back-to-back financing, and a step-by-step method under OECD Chapter X for pricing intra-group loans, guarantees and cash pools. Trigger on: Cyprus transfer pricing, Cyprus local file, Summary Information Table, intra-group loan interest rate Cyprus, back-to-back loan Cyprus, Cyprus safe harbo

mkdir -p ~/.claude/skills/cy-transfer-pricing
curl -L https://claudskills.com/skills/cy-transfer-pricing/SKILL.md \
  -o ~/.claude/skills/cy-transfer-pricing/SKILL.md

@misc{cy-transfer-pricing-2026,
  author    = {openaccountants},
  title     = {Cy Transfer Pricing [Claude Code skill]},
  year      = {2026},
  publisher = {ClaudSkills},
  url       = {https://claudskills.com/skills/cy-transfer-pricing/}
}