Cyprus transfer pricing: the Summary Information Table is due 30 November 2026, and the Local File rules change for 2026
One related-party invoice is enough to put a Cyprus company inside the transfer pricing rules. What the Summary Information Table is, when a Local File is needed, the 2026 thresholds and what a miss costs.
Written by Andreas AchilleosAdvisory & VAT Lead · CFA Charterholder
Every Cyprus company that traded with a related party in 2024 must file a Summary Information Table with its 2024 tax return by 30 November 2026, whatever the amounts. A full transfer pricing Local File is needed only above EUR 5 million of financing or EUR 1 million per other category. A late table costs EUR 500.
Transfer pricing is usually filed under “multinationals”. In Cyprus it reaches much further down. A shareholder loan, a management fee from a parent, a licence from a sister company or goods bought from a group supplier are all controlled transactions, and each one puts the company inside article 33 of the Income Tax Law. This article sets out what that means in practice for an owner-managed or mid-sized company, with the dates that matter this quarter.
Who counts as a related party?
Two companies are related when one holds, directly or indirectly, at least 25% of the voting rights or share capital of the other, or when the same person or group of persons holds 25% in both. A company and its controlling shareholder are related parties.
From 1 January 2026 the definition also catches a director or consultant who, alone or together with other connected persons, holds at least 50% of the voting rights in board decisions, whether through the articles or through a shareholder authorisation. That change came with the December 2025 tax reform and applies to the 2026 tax year onwards.
What is the Summary Information Table and who must file it?
The Summary Information Table (often shortened to SIT) is an annual electronic form listing every controlled transaction of the year: the counterparty, its tax residence, the category of transaction (goods, services, financing, intangibles, other) and the amount.
There is no value threshold. A company with a single related-party transaction files it. It is submitted electronically together with the company income tax return (TD4) by the return’s deadline, and the taxpayer stays responsible for it even when an auditor or adviser prepares it. The table is prepared by reference to the tax year, not the company’s accounting period.
A table filed late carries a fixed fine of EUR 500.
When is the 2024 table due?
30 November 2026. The 2024 company return was extended to that date by Decree K.D.P. 359/2025, and the Summary Information Table follows the return. The Tax Department’s own deadline table shows the 2024 TD4 at 30 November 2026.
The deadline is 30 November 2026. For most companies the 2024 audit has to be signed before the return can be filed, so the working deadline is earlier. The other dates closing out the year are in our Cyprus tax calendar 2026.
When does a company also need a Local File?
The Summary Information Table is a disclosure. The Local File is the full transfer pricing study behind it: functional analysis, method, comparables and the arm’s length result for each category.
A Local File is required when the aggregate value of controlled transactions in a category exceeds the threshold for the year, or would have exceeded it had the transactions been priced at arm’s length. The thresholds depend on the tax year being filed:
| Category | Tax years 2022 to 2025 | Tax years from 2026 |
|---|---|---|
| Financing (loans, cash advances, guarantees) | EUR 5,000,000 | EUR 10,000,000 |
| Sale or purchase of goods | EUR 1,000,000 | EUR 5,000,000 |
| Services, intangibles (royalties, licences) and other | EUR 1,000,000 each | EUR 2,500,000 |
Two points catch companies out:
- The thresholds are per category, in aggregate. Three loans of EUR 2 million each are one financing category of EUR 6 million. For loans, the amount tested is the principal plus any interest charged but not yet paid.
- The 2024 and 2025 returns use the old thresholds. The higher 2026 figures came in with the December 2025 reform and apply from the 2026 tax year. A company filing its 2024 return this November tests against EUR 5 million and EUR 1 million.
A Master File is needed only where the Cyprus company is the ultimate or surrogate parent of a group inside country-by-country reporting, broadly consolidated revenue above EUR 750 million. Few Cyprus owner-managed groups are in that position.
What does the Local File have to look like, and by when?
The Local File must exist by the return deadline, so for 2024 by 30 November 2026, although it is not filed. It is handed to the Tax Department within 60 days of a request. It also has to be reviewed by a holder of an ICPAC practising certificate, who issues a quality review certificate that accompanies the return.
The penalties for not producing it on request escalate with time:
| Produced | Fine |
|---|---|
| Days 61 to 90 after the request | EUR 5,000 |
| Days 91 to 120 | EUR 10,000 |
| After day 120, or not at all | EUR 20,000 |
What if the company is below every threshold?
It still has to show its prices are at arm’s length, in a lighter form. Under the Tax Department’s circular of 6 July 2023 (Circular 6/2023), companies below the Local File threshold keep simplified documentation on file: a brief functional analysis, the resulting characterisation of the company, the reasons for the pricing method chosen, and the arm’s length price with the analysis behind it. It is not filed, but it must be available within 60 days of a request.
The same circular offers optional safe harbours for the commonest small-group transactions:
- Loans to related parties funded by borrowings: a minimum pre-tax return of 2.5% after allowable expenses.
- Loans to related parties funded from the company’s own capital: at least the 10-year government bond yield of the borrower’s country, at 31 December of the previous year, plus 3.5%.
- Borrowings from related parties used in the business: a cost of borrowing no higher than the Cyprus 10-year government bond yield plus 1.5%.
- Low value-adding services: a 5% mark-up on the relevant costs.
A company using a safe harbour declares it in the return and the Summary Information Table, and cannot use one where it holds reliable internal comparables. Using a safe harbour in a cross-border transaction is a reportable arrangement under the DAC6 rules (hallmark E.1), so the choice is not free of paperwork. This is the section to take advice on before adopting.
What should a company do before 30 November?
- List every related-party transaction of 2024, including interest-free shareholder loans and unpaid management charges. If the list is empty, there is no table to file; if it has one line, there is.
- Total each category and test it against the 2022 to 2025 thresholds. Above a threshold, the Local File and its quality review must be ready by the filing date.
- Below the thresholds, confirm the simplified documentation exists for 2024, and decide whether a safe harbour is being relied on.
- File the table with the TD4 by 30 November. The audit timetable, not the tax calendar, is usually the constraint.
- Plan 2026 on the new thresholds and the new connected-person test, and check the 2026 provisional tax estimate while the figures are open; the provisional tax guide covers the 31 December revision.
If our team prepares your return, the table is part of that work. If not, talk to our corporate tax team before the audit closes, because the table is built from the same ledgers.
This article is general information on Cyprus tax rules, not advice on your position. The right answer depends on your structure, your residency and the type of income, so treat it as the start of a conversation rather than the end of one.
