cross-border reporting

DAC6 Law enters into force in Cyprus

On March 18, 2021 the House of Representatives of the Republic of Cyprus approved the Law on Administrative Cooperation in the field of Taxation (Law N. 205(I)/2012) (hereinafter referred to as the “Law”) implementing the EU Directive 2018/822 (DAC6) on mandatory reporting and exchange of information of cross border arrangements.

The Law was published in the Official Gazette of the Republic of Cyprus on the 31st March 2021. It is effective from January 1, 2021 with retroactive effect covering transactions from June 25, 2018 and onwards.

Recent announcements made by the Cyprus Tax Department i.e. the extension of the deadline for DAC6 submissions to 31 March 2021 and the non-imposition of administrative fines for overdue submission of DAC6 Information made up until 30 June 2021 shall remain in place irrespective of the enactment of the Law.

In relation to the above mentioned, on February 26, 2021 the Cyprus Tax Department announced that there will be no imposition of administrative fines for overdue submission of reportable cross border information that will be submitted until the 30th June 2021, for the following cases:

(a) Reportable cross-border arrangements that have been made between 25 June 2018 and 30 June 2020 which had to be submitted by the 28th of February 2021.

(b) Reportable cross-border arrangements that had been made between 1 July 2020 and 31 December 2020 which had to be submitted by the 31st of January 2021.

(c) Reportable cross-border arrangements made between 1 January 2021 and 30 May 2021, that had to be submitted within 30 days from the date they were made available for implementation or were ready for implementation or the first step in the implementation has been made, whichever occurred first.

(d) Reportable cross-border arrangements for which secondary intermediaries provided aid, assistance or advice, between 1 January 2021 and 30 May 2021 and had to submit information within 30 days beginning on the day after they provided aid, assistance or advice.

More details regarding the DAC6 provisions such is what is considered cross-border arrangement, what is reportable can be found on our previous article “Cypriot Implementation of DAC6 approaching” published on December 27, 2019.

For further information and clarifications please contact us via email at or via telephone +357 22262108