Documentation and compliance

Most jurisdictions operate a layered documentation regime built on the OECD three-tier model — a Master File for the group, a Local File for each entity, and country-by-country reporting for large groups — with local variations in thresholds, deadlines and penalties. We prepare the full set, in a form built to be defended rather than merely filed.

Local File — entity overview, management and reporting structure, business strategy, description and quantification of each controlled transaction, analysis of functions performed, assets employed and risks assumed, selection and justification of the most appropriate method, comparability and economic analysis, and financial information reconciled to the statutory accounts.

Master File — for ultimate or surrogate parent entities of groups within the scope of country-by-country reporting, covering organisational structure, business description, intangibles, intra-group financial activities and the consolidated tax position.

Country-by-Country Reporting — notification and report preparation for in-scope groups.

Cyprus-specific requirements — the Summary Information Table, submitted electronically with the corporate income tax return by all persons engaged in controlled transactions, including those below the Local File thresholds; and simplified documentation for transactions falling below the threshold applicable to their category.

Other jurisdictions — documentation and related filings for entities in Greece, Russia and the wider CIS and the UAE, prepared to local requirements. Where both ends of a transaction require documentation, we prepare both, so the position taken in each jurisdiction is consistent with the other.