26/10/2026
The Cyprus Tax Department announced a new obligation to complete and submit a Financing Transactions Table, starting from tax year 2026. The table must also go through a quality assurance check before it is submitted.
What Is the Financing Transactions Table?
The table is a standardised form in which taxpayers disclose specific information taken from their Cyprus Master File on the pricing of controlled financing transactions.
Who Needs to Submit It?
The table is submitted by all persons whose controlled transactions in the category "Financing Transactions" cumulatively exceed, or would exceed on an arm's length basis, the threshold set in Article 33(9) of the Law.
Which Transactions Go in the Table?
Controlled financing transactions are recorded in the table when, after they have been accurately delineated, their remuneration for arm's length purposes is determined through an interest rate. This applies regardless of the amount of each individual transaction.
Provision of financing:
- Loans receivable
- Trade receivables of a financing nature
- Other receivable amounts of a financing nature
Receipt of financing:
- Loans payable
- Trade payables of a financing nature
- Other payable amounts of a financing nature
How Is It Completed and Submitted?
- Mandatory Excel file: the Tax Department has prepared a standard Excel file with automated validation checks. Using it is compulsory, and the table must be submitted only through this file
- Completion guide: a guide with detailed instructions and examples is also available. Both the Excel file and the guide are published on the Tax Department's website
- Electronic submission: the table is submitted through the Tax For All (TFA) system, as an attachment to the Summary Information Table of Controlled Transactions
Quality Assurance Check Before Submission
The information and the results of the comparability analysis shown in the table form part of the Cyprus Local File therefore the table must also undergo a quality assurance check before it is submitted.
The check must be carried out by a person who holds a practising certificate issued by ICPAC.
What This Means in Practice
If your group has intra-group loans, financing-type receivables or payables involving Cyprus entities, it is worth acting early:
- Check whether you are in scope by adding up your controlled financing transactions for 2026 against the Article 33(9) threshold
- Gather the data on all loans and financing-type balances, in both directions, along with the interest terms applied to each
- Download the Tax Department's Excel file and guide and run a first draft well before the submission date
- Line up the quality assurance check with a qualified professional in good time, since it must be completed before the table is filed
- Align the table with your Cyprus Local File, as the two need to tell the same story
PGE&Co remains at your disposal for any clarifications and for further assistance that might be needed on this or on any other matter.