On 3 June 2021, the Cyprus Tax Department (CTD) announced that there will be no imposition of administrative fines for overdue submissions of DAC6 information up until 30th September 2021.

The extension applies to the following cases:

1. Reportable cross-border arrangements (RCBAs) made between 25 June 2018 and 30 June 2020, which had to be submitted by 28 February 2021

2. RCBAs made between 1 July 2020 and 31 December 2020, which had to be submitted by 31 January 2021

3. RCBAs made between 1 January 2021 and 31 August 2021, which had to be submitted within 30 days from the date they were made available for implementation or were ready for implementation or the first step in the implementation had been made, whichever occurred first; and

4. RCBAs for which secondary intermediaries provided aid, assistance or advice, between 1 January 2021 and 31 August 2021 and which had to submit information within 30 days, beginning on the day after they provided the relevant aid, assistance or advice.

The Announcement also clarifies the CTD’s expectation that under section 7D(13)(a) of the Administrative Cooperation in the Field of Taxation Law 2012, i.e. the Cypriot transposition of DAC6, the information to be submitted for RCBAs should include information on persons that are associated enterprises of the relevant taxpayer. Consequently, information should be provided for companies and individuals who are direct shareholders of the relevant taxpayer.

The CTD’s announcement can be found here.