CPM

Cyprus’ credit rating restored to ‘A’ grade by Moody’s

(Source: CyprusMail) Ratings agency Moody’s on Saturday restored Cyprus’ credit rating to its ‘A’, specifically giving the island a score of ‘A3’, restoring the island to the ‘A’ grade for the first time since 2011. The agency explained that Cyprus has “significantly reduced its public debt ratio since its peak in 2020 and ranks among the countries with the largest debt ratio reductions worldwide”. To this end, it said, the upgrade in the island’s rating “reflects a significant improvement in fiscal metrics and debt which we expect to be maintained,” adding that it also expects Cyprus’ debt ratio to continue to decline over the medium term. It added that Cyprus’ medium-term economic outlook is “stable”, noting that it expects banking sector risks to remain “contained” due to the “significant strengthening” of Cypriot banks’ credit profiles in recent years and the continued deleveraging of the island’s banking sector. Reacting to the news, President Nikos Christodoulides described the ratings upgrade as “of exceptional importance”. He expressed his pride in Cyprus’ economy’s “steady upward trajectory”, and was swift to point out that Cyprus’ growth rate is among the highest in the European Union. He put this growth down to “responsible fiscal policy, the stability of the financial sector, and continuous reforms”, all of which, he said, “are at the core of our policies and are bringing positive results”. “Today’s great success is the result of a collective effort, and primarily a result of the Cypriot people,” he added. He went on to say that the upgrade “paves the way for significant prospects, while also making us a more attractive option for quality investments which will contribute to the creation of new jobs”. Additionally, he said, it will bolster “the government’s efforts to establish our country as a reliable and quality investment destination”. To achieve this, he said the government will now attempt to achieved “more dynamic economic growth, strengthened competitiveness, as well as the continuation and strengthening of targeted social measures and actions which aim to improve Cypriot citizens’ everyday lives.” Finance Minister Makis Keravnos said he was “satisfied” by the ratings upgrade, saying it has come about as “the result of prudent economic and fiscal policy implemented by the government.” “This policy allows us to create secure conditions in the economy for people and entrepreneurs and to implement a social policy which supports and relieves vulnerable groups and the working and middle class,” he added. The ratings upgrade comes three weeks after the government elected to end the across-the-board electricity subsidy, with Keravnos having long insisted that it is across-the-board financial support measures which scare off investors. He had said Cyprus received “strict warnings” from the European Commission against implementing and extending across-the-board economic measures, with targeted measures for vulnerable sections of society now favoured. The European Commission were not alone in issuing such warnings, however, with Keravnos saying in March that the International Monetary Fund “told us we have to stop them”, with regard to across-the-board measures to ease the cost of living. These sentiments were ratified by the IMF’s deputy chief Alex Pienkowski, who at the time called on the Cypriot authorities to “resist” any further expansion of “non-targeted reductions in excise taxes and VAT”.

Implementation of Good Practices on Gender Equality in the Working Environment (Equality Employer)

We are excited to share that Cyproman Services Ltd has proudly awarded the renewal of the certification for the Implementation of Good Practices on Gender Equality in the Working Environment (Equality Employer) by the National Certification Body for Gender Equality and the Department of Labour Relations. Our firm declares its commitment to promoting equal treatment and equal opportunities between men and women at all levels and activities of the firm, practices aiming at strengthening gender fairness and cultivating a friendly and human culture, developing a creative working environment, offering equal training opportunities to all employees, and adopting a non-discriminatory recruitment process.A commitment that is fully aligned with our ethics and philosophy as people are our most valuable assets.

The Innovative Synergy of Living and Working in Cyprus

By our Business Development Department. Cyprus Vision 2035 is a transformative roadmap aimed at positioning Cyprus as a premier destination for business, innovation and high-skilled talent. Central to this vision are strategic initiatives designed to attract international professionals and investors, including the Cyprus Blue Card and IP Regime. Cyprus offers a multitude of benefits for third-country nationals seeking to work and live in Cyprus. Designed to attract highly skilled professionals, this residence permit opens doors to a wealth of opportunities within the European Union. From streamlined immigration process to favourable employment conditions, the Cyprus Blue Card provides a competitive edge in a globalised job market, thus making Cyprus the strategic move for career advancement and personal growth in Europe’s thriving economies. Following the amendments to the Civil Registry Law of Cyprus which came into force on July 2024, the following provisions are of particular importance, as Cyprus sets to lead the way to the synergy of dynamic environment for business development, talent attraction and tax efficiency. Definition of simpler procedures regarding the entry and residence of third-country nationals in the Republic for the purpose of highly qualified employment, as European Union Blue Card holders and their family members; Reduction of the minimum required duration of the employment contract for highly qualified employment purposes, so that it is at least six (6) months instead of at least twelve (12) months, as was previously in force; The process of determining the total number of persons who will be able to enter and reside in the Republic for highly qualified employment purposes, taking into account the development priorities and the situation in the labour market in the Republic, as well as the capacity of the Republic to receive them; Setting of a gross annual salary threshold for European Union Blue Card holders, so that it is at least equal to the average gross annual salary in the Republic, but does not amount to more than 1.6 times the amount of the average gross annual salary in the Republic. Recognition of possession of professional skills in the field of information and communication technologies, i.e. knowledge, skills and competences attested by professional experience, as equivalent to knowledge, skills and competences attested by comparable higher education qualifications; Strengthening the rights of European Union Blue Card holders and their family members. Definition of the procedures that will be applied regarding the mobility of the above mentioned persons, within the European Union; In light of the above and in combination with the IP Regime, Cyprus offers unique and substantial benefits particularly for highly skilled workers in the technology, innovation and intellectual property sectors, seeking to capitalize on Cyprus’ favourable tax environment and talent-friendly immigration polices. Attracting Skilled workers in IP-Intensive Sectors. The Cyprus Blue Card is a residence permit for highly skilled third-country nationals. It facilitates the hiring of professionals in sectors like technology, innovation and IP. Regime, which with its tax incentives for IP income, makes Cyprus a favourable destination for companies engaged in research, innovation and IP-related activities, attracting both companies and professionals; Favourable Tax Treatment for IP-related income: The Cyprus IP Regime provides an 80% tax exemption on profits derived from the exploitation of IP assets. This includes royalties, license fees and capital gains from the disposal of qualifying IP. Furthermore, highly skilled employees with a Cyprus Blue Card working in companies which own or develop IP, can benefit from a favourable tax regime as their companies can significantly reduce their corporate tax liability and potentially increase wages and/or benefits; Low Personal Income Tax for Blue Card holders: Especially those with high salaries, may benefit from Cyprus’ tax incentives for high-income earners (50% income tax exemption for employees earning over €55,000 annually. This makes Cyprus an attractive destination for professionals who are key contributors to IP-related work (R&D, innovation, etc), where high salaries are common; Innovation-Driven Business Environment: The combination of the Blue Card with the IP Regime, promotes Cyprus as a hub for start-ups and tech companies attracting international talent, with the ultimate goal to maximize profits and grow their business. This very environment supports knowledge-based industries, where IP assets are central, thus making Cyprus attractive for IP developers and innovators; European Market Access: Blue Card holders benefit from the free movement within the EU for work purposes. This is a major advantage for IP professionals as it allows them to collaborate across the EU countries and access a wider market, while Cyprus serves as their base of operations. Coupled with the IP Regime’s tax benefits, professionals and companies can use Cyprus as a strategic location for handling their IP, while also having access to the broader EU market; Long-Term Residency and Stability: The Cyprus Blue Card as the way to permanent residency and further provides social benefits. Professionals in the IP sector can enjoy stability while living in Cyprus, thus making it easier for them to focus on long-term R&D projects, IP development and innovation strategies, while also benefiting from Cyprus’ favourable tax regime; Cost-efficient IP Management: Cyprus offers relatively low costs of living and business operations, especially compared to other EU countries. This benefits both the Blue Card holders and companies under the IP regime, making the overall cost of running IP intensive businesses more efficient, while still benefiting from the high-quality talent. Comprehensive Legal Protection for IP: Cyprus has a robust legal framework for the protection of IP rights, which is crucial for companies and professional working with valuable intellectual property. Coupled with the tax incentives, this makes Cyprus an appealing location for establishing and exploiting IP assets;

Maria Panayiotou: FinTech and RegTech are transforming the way fund management companies operate

(Source: InBusinessNew 24/10/2024) Maria Panayiotou, President of the Cyprus Investment Funds Association (CIFA), believes it is is time to attract more foreign investment into Cyprus, while also facilitating investments from Cyprus into other market, as she has great confidence in the abilities and business acumen of the professionals and companies based on the island. In an interview with GOLD magazine, she discusses CIFA's role at the forefront of legislative advocacy and strategic development for Cyprus' investment funds sector, and its commitment to fostering a resilient and innovative financial ecosystem. CIFA has urged the swift passage of a bill through Parliament concerning the establishment and operation of Fund Administration Companies for Collective Investment Organisations. What is the significance of this bill for the investment funds sector? The bill is a crucial development for Cyprus’ investment fund sector. It completes the sector’s legislative framework, which is essential in an environment where regulatory and legal certainty are increasingly demanded by investors and market participants. The bill introduces a layer of security that reassures investors about the integrity of fund operations and ensures that administrators adhere to high standards. Moreover, it positions Cyprus as a more attractive hub for fund administration by aligning its regulatory environment with global standards. This creates confidence in both domestic and foreign investors, boosting the sector’s growth. CIFA has been at the forefront of pushing for these legislative updates, and its collaboration with CySEC (Cyprus Securities and Exchange Commission) and the House of Representatives reflects the sector’s willingness to continuously modernise and adapt. That said, a potential challenge that comes with this bill concerns the sector’s ability to keep up with continuous regulatory changes. The global investment landscape is very dynamic and the regulations governing it are constantly evolving in response to technological advancements and changes in investor behaviour. So, while the new bill is a positive step, it is also imperative that the sector remains flexible and proactive in its regulatory approach. CIFA projected a positive outlook for Cyprus’ investment funds sector in 2024. As we approach 2025, to what extent has the sector’s actual performance this year aligned with your expectations? Despite numerous global challenges, including geopolitical tensions and fluctuating economic conditions, Cyprus’ investment fund sector has remained resilient throughout 2024. It has experienced growth and played a key role in the country’s economic stability. The sector not only saw an increase in activity but also contributed to the creation of new business opportunities and jobs, generating significant revenue for the Government. In a year when high lending interest rates have made traditional financing less accessible, the investment funds sector has proven to be a critical source of financing for major projects in Cyprus. This demonstrates the sector’s adaptability and ability to thrive, even when faced with challenging external conditions. Looking to 2025, the performance in 2024 serves as a strong foundation for continued growth. The sector’s ability to weather these challenges reinforces its importance to Cyprus’ broader economy and signals a positive outlook moving forward. How has the rise of technology and the digital transformation influenced the investment funds sector in Cyprus? The rise of technology and the digital transformation has had a profound impact on the investment funds sector in Cyprus, just as it has in other parts of the world. FinTech and RegTech are transforming the way fund management companies operate. These technologies improve operational efficiency, reduce costs and make compliance with regulatory requirements much more straightforward. The use of automation and AI-powered tools allows fund managers to analyse vast amounts of data quickly, providing them with better insights for decision-making. Additionally, RegTech solutions help companies stay compliant with the constantly evolving regulatory landscape by automating reporting and ensuring that all necessary filings are completed accurately and on time. CIFA recognises that embracing these technological advancements is essential to remain competitive on a global scale. Companies that fail to adapt risk falling behind, as technology has become a critical driver of success in the investment funds industry. How does CIFA collaborate with global financial institutions and regulatory bodies to ensure that Cyprus remains aligned with international best practices in fund management and governance? CIFA’s collaboration with international financial institutions and regulatory bodies is a key factor in ensuring that Cyprus remains aligned with global best practices in fund management and governance. The Association is a member of several prominent organisations, including the European Funds and Asset Management Association, the International Investment Funds Association, and the International Capital Market Association. These memberships provide Cyprus with access to the latest developments in the global fund management industry and ensure that the country’s regulatory framework is in line with international standards. Moreover, CIFA works closely with CySEC and the European Securities and Markets Authority (ESMA) to ensure that Cyprus continues to adopt the latest regulatory updates. This proactive approach to regulation is crucial in maintaining the trust of investors and ensuring that the investment funds sector in Cyprus remains competitive on a global scale. Cyprus is often seen as a strategic gateway for investment into Europe, the Middle East, and Africa. How is the investment funds sector capitalising on this unique geographical location and what steps is CIFA taking to strengthen these connections? While Cyprus’ geographical location as a gateway to Europe, the Middle East, and Africa has traditionally been one of its competitive advantages, its significance is evolving in the modern world. In today’s globally connected environment, physical location is becoming less important than factors such as political and economic stability, regulatory compliance and the quality of services offered. However, Cyprus still stands out as a strategic location due to its combination of advantages, including its European Union membership, political stability and high standard of living. These factors make it an attractive destination for investment funds looking to access the broader European market while also tapping into opportunities in the Middle East and Africa. CIFA is actively working to strengthen these connections by promoting Cyprus as an ideal destination for investment funds. Looking ahead, what do you see as the major opportunities and challenges for Cyprus in the next five to ten years in terms of investment? What industries or sectors do you expect to drive future growth? Cyprus will face both opportunities and challenges in the next five to ten years. One of the main challenges concerns the global economic and geopolitical environment. As a small, open economy, Cyprus is highly susceptible to external shocks and any significant disruptions in the global economy could have a substantial impact on its investment funds sector. Internally, one of the biggest challenges concerns the modernisation of the state apparatus to make it more business-friendly. This includes simplifying administrative processes, improving the speed of decision-making and increasing the use of technology to improve efficiency. If Cyprus can address these internal challenges, it will be well-positioned to remain competitive globally. In terms of opportunities, industries such as renewable energy, technology and financial services are expected to drive future growth. These sectors offer significant potential for investment and Cyprus is in a strong position to capitalise on these opportunities. On a more personal note, this is still your first year as President of CIFA. What are the main objectives you hope to achieve during your term of office? My primary objective, along with the CIFA Board, is to create a new ecosystem that will not only bolster the service sector but also contribute to the broader Cypriot economy. I have great confidence in the abilities and business acumen of the professionals and companies based in Cyprus, and I believe it is time to attract more foreign investment into Cyprus, while also facilitating investments from Cyprus into other markets. Additionally, one of the critical challenges we are addressing is the need to modernise the way citizens approach financial management. The financial practices of previous generations no longer serve us well in today’s complex economic environment. In this respect, we aim to educate the public on how to take advantage of the services offered by investment funds to better manage their personal and family finances.

Alert , 2022 Employment Tax Incentives-New income tax exemptions for first employment in Cyprus

On 14 July 2022, the House of Representatives voted amendments to Articles 8(21) and 8(23) of the Income Tax Law (ITL) related to the income tax exemptions granted to employees who take up first employment in Cyprus. The amended provisions of the Law have been published in the Government Gazette on 26 July 2022. These amendments form part of a wider strategy of the Cyprus Government for attracting both international investments and diversified talent. Moreover, such amendments complement the recent changes in the migration rules which simplify and expedite the relocation of staff and their families from EU and non-EU countries. The new 50% exemption (Article 8(23A)) The provisions of the new Article 8(23A) of the ITL apply as from 1 January 2022 for individuals who take up first employment in Cyprus commencing on or after 1 January 2022 provided that the following conditions are satisfied: • The individuals were not tax resident of Cyprus for a period of at least 10 consecutive years prior to the commencement of their employment in Cyprus; and • Their annual remuneration from exercising their employment in Cyprus exceeds the threshold of €55.000. The exemption is granted in any tax year where the €55.000 threshold is satisfied. The exemption can also be granted (subject to special rules) in the first and final tax year as well as in cases where the annual remuneration fluctuates below the annual threshold of €55.000. The exemption is available once in a lifetime for a maximum period of 17 years starting from the tax year of taking up first employment in Cyprus. It should be noted that this exemption does not require the individuals to become Cyprus tax residents. Moreover, individuals claiming this exemption cannot also claim the existing 50% exemption (Article 8(23)), the existing 20% exemption (Article 8(21)) or the new 20% exemption (Article 8(21A)). Transitional provisions Moreover, individuals who took up employment in Cyprus prior to January 2022, may also be eligible to transition themselves and claim an exemption as per the new Article 8(23A) as shown below: Year of commencement of 1st employment Eligible persons Prior to 2022 Individuals who benefited from the existing 50% exemption (Article 8(23)) and continuously exercised their employment in Cyprus up to and including 2021 Between 2016 and 2021 Individuals whose annual remuneration from first employment in Cyprus exceeded €55.000 Individuals whose annual remuneration from first employment in Cyprus did not exceed €55.000 and within 6 months, starting from 26th July 2022, their remuneration will exceed the €55.000 threshold Individuals currently benefiting under the existing 50% exemption (Article 8(23)) and do not fall within any of the cases mentioned above will continue to benefit from the existing 50% exemption up until the completion of the 10 year period. It should be noted that the provisions of Article 8(23) apply for individuals taking up first employment in Cyprus up until 26th July 2022. The new 20% exemption (Article 8(21A)) Under the provisions of Article8 (21A), which are applicable as from 26th July 2022, individuals who take up first employment in Cyprus after 26th July 2022 are eligible to claim a 20% exemption on their annual remuneration (capped at €8.550) for a maximum period of 7 years. Individuals claiming the new 20% exemption should have been non-Cyprus tax residents for at least 3 consecutive years prior to the commencement of first employment in Cyprus and must have been employed outside of Cyprus by a non- resident employer. The exemption can be claimed in the tax year following the tax year of commencement of first employment in Cyprus (i.e. if first employment commences in 2022, the 20% exemption is granted from tax year 2023 up until tax year 2029). Individuals already benefiting from the 50% exemption will not be eligible to additionally claim the 20% exemption. Individuals who are currently eligible under the existing 20% exemption (Article 8(21)), and who are not eligible for the transitional provisions (mentioned above) will continue to benefit from the existing 20% exemption up until the completion of the 10 year period.

Alert 2, 2021 UBO Register of Trusts and of similar legal arrangements

Cyprus implements Beneficial Ownership Register for trusts and similar legal arrangements Further to the introduction of the register of Beneficial Owners (BOs) for companies, on the 18 June 2021 Cyprus has introduced a similar register for BOs of Trusts and other similar legal arrangements (the “Trust Register”) to be kept electronically by the Cyprus Securities and Exchanges Commission (CySEC) which is the supervisory authority for the implementation and operation of the Trust Register. The Trust Register was implemented through CySEC’s Directive for the prevention and suppression of money laundering and terrorist financing (register of beneficial owners of express trusts and similar legal arrangements) (the “Directive”) which provides information and guidance in relation to the registration of express trusts and similar legal arrangements in the Trust Register. The Directive applies for express trusts which are defined as trusts created expressly by a settlor at his own will. Trusts arising by operation of law as well as trusts for which the settlor shows no clear intention for their creation are not considered to be express trusts. Registration of an express trust should take place in cases where: the trustee is located or residing in the Republic of Cyprus; or the trustee, which is located or residing outside EU, establishes a business relationship or acquires immovable property in Cyprus on behalf of the express trust. Information to be submitted The following information must be submitted for registration: For the trusts and other similar legal arrangements Name of the trust Country and date of establishment Applicable law Termination date (if applicable) Country in which the trustee is established or resides and details of his address In case the trustee resides outside the EU and establishes a business relationship on behalf of the trust in Cyprus, the date of commencement of the business relationship, the name of the person with whom such relationship is established together with the document which governs such a relationship In case the trustee resides outside the EU and acquires immovable property on behalf of the “Stated” (expressed) trust in Cyprus, the registration number and address of the immovable property together with the title deed of the property Any other information and/or supporting documentation requested by CySEC for identification purposes BO/s (trustee, settlor, protector, beneficiaries) Name, surname and father’s name Date and place of birth Nationality/ies Residential Address Type, number and country of issuance of identification document Date of death (where applicable) Date on which the person became beneficial owner The nature and extent of the rights which are directly or indirectly held by the UBO The role of the UBO in the trust or in a similar legal arrangement Any other information and/or supporting documentation requested by CySEC for identification purposes In case the Trust has one or more classes of beneficiaries, the following information should also be provided: Description of the class of beneficiaries and its members the nature and extent of the rights of each class of beneficiaries Deadlines and Charges A six-month period has been granted for existing trusts to be registered. For new trusts falling under either of the two cases, as well as for any changes in the information submitted to the Trust Register for trusts already registered, there is a time limit of 15 days from the date of appointment of the trustee or the date on which such changes were effected. CySEC has set a scale of charges for registration and renewal of registration of trusts as well as for retrieving information. Eligible persons/authorities for having access in the UBO trust register Eligible for having access without any charge to the information entered in the Trust Register will be the trustees and or any other equivalent person who has entered such information thereinto, as well as other competent authorities like the Unit for Combating Money Laundering and Terrorist Financing, the police, the Customs’ Department, and the Tax Department. Furthermore, any person or organization who may demonstrate a legitimate interest and who provides sufficient evidence in this respect , may have access to such information under a fee if the relevant application submitted to CySEC is approved. The procedure is set as follows: CySEC acknowledges with the trustees and or the equivalent person of the receipt of an application from a certain person/authority and the fact that they have initially established that indeed such a person or authority has a legitimate interest. If the trustees do not file written representations within 10 days as of the date it has received CySEC’s acknowledgment, then such a person and or authority will be given access to the information kept in the Trust Register.

Alert 2, 2021 UBO Register Of Trusts And Of Similar Legal Arrangements

Cyprus implements Beneficial Ownership Register for trusts and similar legal arrangements Further to the introduction of the register of Beneficial Owners (BOs) for companies, on the 18 June 2021 Cyprus has introduced a similar register for BOs of Trusts and other similar legal arrangements (the “Trust Register”) to be kept electronically by the Cyprus Securities and Exchanges Commission (CySEC) which is the supervisory authority for the implementation and operation of the Trust Register. The Trust Register was implemented through CySEC’s Directive for the prevention and suppression of money laundering and terrorist financing (register of beneficial owners of express trusts and similar legal arrangements) (the “Directive”) which provides information and guidance in relation to the registration of express trusts and similar legal arrangements in the Trust Register. The Directive applies for express trusts which are defined as trusts created expressly by a settlor at his own will. Trusts arising by operation of law as well as trusts for which the settlor shows no clear intention for their creation are not considered to be express trusts. Registration of an express trust should take place in cases where: The trustee is located or residing in the Republic of Cyprus; The trustee, which is located or residing outside EU, establishes a business relationship or acquires immovable property in Cyprus on behalf of the express trust. Information to be submitted The following information must be submitted for registration: For the trusts and other similar legal arrangements Name, surname and father’s name Date and place of birth Nationality/ies Residential Address Type, number and country of issuance of identification document

Alert 1, 2021 Cyprus law to implement Mandatory Disclosure Rules enters into force

On 31 March 2021, the law (Ν. 41(Ι)/2021, the Law) amending the Law on Administrative Cooperation in the field of Taxation (Law N. 205(I)/2012) was published in the Official Gazette of the Cyprus Republic and entered into force. The Law transposed the European Union (EU) Directive (referred to as DAC6 or the Directive) into domestic law. The Law entered into effect as of 1 January 2021, however, it will have a retrospective effect for reportable cross-border arrangements concluded on or after 25 June 2018 provided that one of the prerequisite triggering events is met. The final Cypriot Mandatory Disclosure Rules (MDR) legislation is broadly aligned with the requirements of the Directive with minor differences. Further to the Law, guidance notes will be issued by the Cypriot Tax Department (CTD) to provide clarity over the interpretation of key terms of the Law. The Directive requires intermediaries (including EU-based tax consultants, banks, asset managers, corporate administrative service providers, insurance companies and lawyers) and in some situations, taxpayers, to report certain cross-border arrangements (reportable arrangements) to the relevant EU member state tax authority. This disclosure regime applies to all taxes except value added tax (VAT), customs duties, excise duties and compulsory social security contributions. Cross-border arrangements will be reportable if they contain certain features (known as hallmarks). Under the Directive, an arrangement is reportable if: The arrangement meets the definition of a cross-border arrangement; and The arrangement meets at least one of the hallmarks A-E specified in Annex IV of the Directive and the main benefit test (MBT), where applicable. Administrative fines for non-compliance Breach Penalty (one-off administrative fine per entity and arrangement) Failure to report a Reportable Cross Border Arrangement (RCBA) €10.000-20.000 Delay in reporting an RCBA Up to 90 calendar days: €1.000-5.000 More than 90 calendar days: €5.000-20.000 Filing inaccurate or incomplete or misleading report of an RCBA €1.000-10.000 Failure to notify other intermediaries or the relevant taxpayer by the intermediary regarding the exemption due to Legal Professional Privilege (LPP) €10.000-20.000 Delay in the notification of other intermediaries or the relevant taxpayer by the intermediary regarding the exemption due to LPP Up to 90 calendar days: €1.000-5.000 More than 90 calendar days: €5.000-20.000 Failure to provide the Cypriot Tax Department with information or documents for an arrangement within 14 days from the date of reception of written notice €1.000-10.000 Failure to pay the administrative fines imposed/Continuance of the relevant breach Increase of imposed fine up to €20.000 As implied by the provisions of the Law, penalties will also apply for intermediaries/relevant taxpayers who have breached their reporting or notification obligations, as prescribed in the Law, for the transitional period. On 4 June 2021, the CTD announced the non-application of administrative penalties for all filings effected by 30 September 2021 in respect of RCBAs made or to be made from 25 June 2018 up until 31 August 2021. As from 1 September 2021, RCBAs should be reported within 30 days from the rom the relevant triggering event. Remarks Cyprus intermediaries and taxpayers with cross border arrangements should review their existing procedures to continuously monitor their disclosure obligations under the DAC 6, ensuring compliance and minimising the risk of monetary fines.