Transfer pricing documentation and benchmarking for Cyprus groups, technology businesses, IP structures and cross-border transactions — from minimum documentation to full Local Files 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.