OUR SERVICES

Transfer Pricing Compliance

Transfer Pricing Compliance

Transfer Pricing Compliance

As Cyprus tightens its transfer pricing framework, groups with cross-border transactions must ensure that pricing and documentation meet local expectations. Our transfer pricing services help you comply while keeping structures practical and aligned with your commercial reality.

APPLICABILITY

APPLICABILITY

When Transfer Pricing Rules Apply

We assess whether your Cyprus entities fall within transfer pricing rules in Cyprus, taking into account transaction types, volumes and relationships.

Assessment Factors

Transaction types

Volumes

Relationships

Assessment Factors

Transaction types

Volumes

Relationships

TRANSACTIONS

TRANSACTIONS

Types of Transactions Covered

Our work covers management fees, financing, royalties, services, distribution margins and cost-sharing arrangements. We align pricing with your global transfer pricing policy while addressing local constraints.

Whole Family Relocation

Management Fees

Financing

Royalties

Services

Distribution Margins

Cost-sharing Arrangements

Whole Family Relocation

Management Fees

Financing

Royalties

Services

Distribution Margins

Cost-sharing Arrangements

DOCUMENTATION

Master File & Local File Requirements

We support the preparation of Cyprus master file requirements and local files, including functional analyses, benchmarking and documentation of intercompany agreements.

Functional Analyses

Detailed analysis of functions performed, risks assumed, and assets used

Benchmarking

Market comparables and arm's length pricing analysis

Intercompany Agreements

Documentation of all related party contracts

Master & Local Files

Cyprus master file requirements and local files preparation

RISK MANAGEMENT

RISK MANAGEMENT

Risk Management & Rulings

Where appropriate, we can explore advance rulings, APAs or other mechanisms to provide certainty. We also assist with audits, queries and disputes related to transfer pricing in Cyprus.

Advance Rulings

Pre-agreement with tax authorities on specific transactions

Advance Rulings

Pre-agreement with tax authorities on specific transactions

APAs

Advance Pricing Agreements for ongoing certainty

APAs

Advance Pricing Agreements for ongoing certainty

Audit Assistance

Support with audits and queries

Audit Assistance

Support with audits and queries

Dispute Resolution

Assistance with disputes related to transfer pricing

Dispute Resolution

Assistance with disputes related to transfer pricing

Certainty & Protection

Advance rulings and APAs provide certainty for your cross-border arrangements

Integration with Tax and Accounting

Transfer pricing must be reflected consistently in contracts, invoices and financial statements. We coordinate with our international tax advisory and accounting teams so that implementation is smooth.

Contracts

Invoices

Financial statements

Get Transfer Pricing Support

Get Transfer Pricing Support

Book a consultation to discuss your group's transfer pricing documentation and compliance requirements.
Book a consultation to discuss your group's transfer pricing documentation and compliance requirements.

Free initial consultation

Response within 24 hours

No obligation

Aqualis, based in Cyprus, is an independent firm of Chartered Accountants and a practicing member of ICPAC and ICAEW.


We offer expert tax, advisory and audit services with integrity and innovation, delivering tailored solutions for the dynamic international markets and guiding businesses.

© Aqualis 2026, all rights reserved.

© Aqualis 2026, all rights reserved.