Tax treatment of non-returnable capital contributions
The Cyprus Tax Department’s Interpretative Circular EE 25 dated 3 September 2018 clarifies the tax treatment of non-returnable capital contributions by Cyprus taxpayers to companies which are tax-resident abroad. Article 33 of the Income Tax Law N.118 (I)/2002 allows the tax authorities to adjust transactions between related entities onto an arm’s length basis and assess […]
