Transfer pricing in Cyprus for groups, technology businesses, IP structures and cross-border transactions — from minimum documentation and benchmarking to Local Files, royalties, financing and transaction-specific studies.
Cyprus applies the OECD arm's-length principle to transactions between connected persons. From 2026, full Local File thresholds are €5 million for goods, €10 million for financing and €2.5 million for services, IP licensing or royalties and other categories.
Threshold relief does not remove the need for arm's-length pricing. We scale the documentation to the transaction and risk profile, keeping agreements, functional analysis, benchmarking and accounting outcomes aligned.
Cyprus Local Files, transaction mapping, functional analysis, method selection, financial testing and annual updates.
Proportionate support for controlled transactions below Local File thresholds, including pricing rationale and agreements.
Royalty-rate analysis for software, platforms and other intangibles, coordinated with DEMPE and IP Box considerations.
Loan pricing, credit analysis, debt capacity, guarantee fees and financing documentation under the OECD financial-transactions framework.
Cost-base review, allocation keys, benefit analysis, mark-up benchmarking and intercompany service agreements.
Transfer pricing analysis for migrations of functions, assets, risks, IP and profit potential between group entities.
Comparable-company and transaction searches, screening, adjustments, interquartile ranges and tested-party analysis.
Documentation review, technical support and coordination of responses where transfer pricing is challenged or queried.
Align development functions, licence arrangements, royalty pricing and nexus evidence so the commercial, TP and IP Box positions are coherent.
Support platform licences, marketing services, operating entities, payment functions and cross-border management charges.
Support financing, guarantees, central services, acquisitions, restructurings and cross-border shareholder arrangements.
We can review the transaction set and confirm the proportionate documentation required.
G. Adamides Audit Ltd is an independent ICPAC-regulated firm in Nicosia. Engagements are led by experienced professionals and coordinated across audit, tax, accounting, corporate, valuation and financial reporting disciplines.
Direct senior involvement from scoping through delivery, with clear accountability and communication.
Experience with international groups, founders, HNWIs, technology, iGaming, fintech and complex cross-border structures.
Corporate documents, accounting records, tax analysis and audit evidence are aligned rather than handled in isolation.
Following the 2026 tax reform, the Local File thresholds are €5 million for sale-of-goods transactions, €10 million for financing transactions and €2.5 million for other categories, assessed by category of controlled transactions and subject to the detailed rules.
Controlled transactions must still satisfy the arm’s-length principle. Cyprus Tax Department guidance provides for Minimum TP Documentation for transactions not required to be documented in a Cyprus Local File, including a functional analysis, method selection and economic support or benchmarking where appropriate.
Yes. We support intra-group software and IP licensing with functional and DEMPE analysis, method selection, royalty benchmarking or valuation evidence, agreement review and alignment with the Cyprus IP Box where relevant.
Yes. We analyse loans, cash pooling, guarantees and other financing arrangements, including credit analysis, interest-rate benchmarking, functional characterisation and OECD-compliant documentation.
Yes. We can prepare or review the Cyprus Local File, benchmarking and supporting analyses, coordinate the annual Summary Information Table process and maintain documentation for future Tax Department review.