job vacancies Nobel Trust Nicosia

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TAX MANAGER

We are seeking to recruit a high caliber person for the position of Tax Manager to be based in our offices in Nicosia.

Role and Responsibilities

  1. Reviewing financial statements and tax returns and advising on tax and VAT matters based on Cyprus laws
  2. Drafting tax rulings and tax memos
  3. Assisting with tax structuring and resolving practically complex tax related issues
  4. Assisting with advice on transfer pricing for international groups
  5. Knowledge of fundamental tax and legal aspects in relation to major foreign jurisdictions and application of Double Tax Treaties
  6. Preparing presentations and publications on practical tax matters
  7. Attending meetings and conducting negotiations with the tax authorities
  8. Correspondence and communication with clients in respect to the above on a daily basis
  9. Assisting with the firm’s business development with a focus on taxation and structuring

The profile of the ideal candidate

  1. At least 3 years post-qualification experience in the field of taxation with a top-tier accounting firm
  2. ACA/ACCA/LLM or equivalent qualification
  3. Good communication, organisational, supervisory, presentation and interpersonal skills
  4. Be a great team-player
  5. Strong computer skills
  6. Strong sense of commitment and responsibility
  7. Good command of Greek and English languages

Remuneration

A competitive remuneration package will be offered to the successful candidate according to his/her qualifications and experience.

Apply now

Please email your CV to the Management at Nobel Trust Ltd : [email protected]

SENIOR ACCOUNTANT

We are seeking to recruit a high caliber person for a responsible position in our Client Accounting Department to be based in our offices in Nicosia.

Role and Responsibilities

  1. Handling a portfolio of clients on a daily basis and dealing with all their accounting affairs
  2. Dealing with VAT, VIES and tax compliance matters
  3. Collecting information and preparing an audit file
  4. Co-ordinating the preparation and filing of financial statements and tax returns
  5. Liaising with the company’s auditors in completing a company’s statutory audit
  6. Review a company’s financial statements and tax returns for accuracy and compliance with IFRSs and tax laws
  7. Review a company’s business activities in the course of internal risk assessment
  8. Correspondence and communication with clients in respect to the above on a daily basis

The profile of the ideal candidate

  1. University degree and ACA or ACCA partly or fully qualified
  2. Minimum 3 years relevant experience
  3. Strong computer skills
  4. Good communication, organisational, supervisory and interpersonal skills
  5. Strong sense of commitment and responsibility
  6. Good command of the Greek and English languages

Remuneration

A competitive remuneration package will be offered to the successful candidate according to his/her qualifications and experience.

Apply now

Please email your CV to the Management at Nobel Trust Ltd : [email protected]

**All applications will be treated in strict confidence.

Transfer Pricing: Cyprus tax system, by Nobel Trust

Transfer Pricing: Amended Legislation in the Cyprus Tax System

Transfer Pricing: Amended Legislation in the Cyprus Tax System

Cyprus tax resident companies engaging in intercompany transactions with related parties fall within the amended Transfer Pricing (TP) regulations which aim to ensure that transactions are conducted at arm’s length. By aligning the Cyprus tax system with the OECD Transfer Pricing Guidelines, the updated regulations establish a solid framework for managing cross-border transactions.

Therefore, if you own or operate a business in Cyprus, it is time to get familiar with the new TP laws and the several important obligations they bring, as they are effective from 1 January 2022.  

Key Definitions

  • Cyprus Tax Residents: Cyprus tax-resident entities and Permanent Establishments (PEs) of non-resident entities engaged in transactions with related parties.
  • Related Parties: Companies or individuals are deemed related if they (a) directly or indirectly hold at least 25% of the voting rights or share capital, or (b) have the right to at least 25% of the profits of a company.
  • Arm’s length principle: Pricing for goods, services, royalties, and loans between related parties must be in line with market conditions.

Reporting Obligations

Entities engaging in such transactions have an obligation to submit a Summary Information table (SIT) regardless of the value of the transactions.

SIT

  • The SIT must be filed together with the annual Income Tax Return.
  • It includes high-level details of intercompany transactions, such as the counterparties involved, categories of transactions, and their value.
  • A €500 penalty is imposed for late or non-submission of the SIT.

In addition, they are required to prepare and keep a record of the relevant TP documentation, being a Local File and Master File, in case they exceed the specified thresholds.

Thresholds

  • Any type of intercompany transaction (i.e., goods, services, intellectual property) exceeding €1.000.000 per category.
  • Financing transactions (i.e., loans) exceeding €5.000.000.

Local File

  • It must be prepared before the tax return filing deadline.
  • It includes a transfer pricing study that demonstrates compliance with the arm’s length principle.
  • It must be submitted to the Cyprus Tax Department (CTD) within 60 days upon request. The penalties for late submission vary from €5.000 to €20.000.

Master File

  • It is required for multinational enterprise groups where Cyprus acts as the Ultimate Parent Entity (UPE) or Surrogate Parent Entity (SPE), and the group meets the Country-by-Country Reporting requirements (with consolidated revenues exceeding €750 million).
  • It provides an overview of the group’s global business operations, organizational structure, and overall transfer pricing policies.
  • It must be submitted within 60 days upon request from the CTD.
  • The penalties for late submission vary from €5.000 to €20.000.

Advance Pricing Arrangement (APA)

An APA provides certainty for taxpayers regarding the application of transfer pricing rules to specific transactions. Businesses can apply for an APA with the Tax Commissioner, where it can pre-approve the TP methods used or the pricing of cross-border transactions.

  • The Tax Commissioner issues a decision within 10 months.
  • The APA is valid for a maximum of four years from the application date.

We understand that the penalties for non-compliance can be significant, therefore it is of high importance to take appropriate action in advance. Our team of experts is here to help you navigate the complexities of the transfer pricing changes. Whether you need assistance in understanding your reporting obligations or preparing the required documentation for your local entity or multinational group, we are ready to support you every step of the way.

Contact us here for more information.