The back-to-back financing arrangement relates to Companies, tax residents of Cyprus, which are acting as financial intermediaries within a Group i e they
Changes-to-the-Back-to-Back-Financing.pdf
3 juil 2017 · intra-group financing arrangements which apply from 1 July “back to back loans” will be terminated as at 30 June 2017
CY_TaxAlerts_3_7_2017EN_Noexp.pdf
intra-group back-to-back financing arrangements ? In addition it covers the granting of loans to related parties out of funds borrowed from other related
transfer-pricing-in-%D1%81yprus.pdf
All transactions (including financing/loan arrangements) between related parties must, for tax purposes, be carried out at arm's length (e g at market rate),
informationsheetno981460445146.pdf
back-to-back financing arrangements Cyprus' Tax Department has issued on the 30th of June 2017 an expository Circular in relation
Tax-alert-Jul-2017.pdf
30 jui 2017 · Tax treatment of intra-group back-to-back financing arrangements This Circular applies to any company carrying out group financing
Back-to-Back-Tax-Dept-Circular-3-EN.pdf
Intragroup loan pricing - the OECD Discussion Draft on Financial Transactions recognised that it is most appropriate for back-to-back financing
TP-of-loans-financial-instruments-November-2018.pdf