EXCHANGE OF INFORMATION BETWEEN THE CYPRUS TAX AUTHORITIES AND CORRESPONDING AUTHORITIES OF FOREIGN STATES

On July 25, 2008 the Ascertainment and Collection of Taxes Law of 1978 was amended by the Ascertainment and Collection of Taxes Law of “Law 72(I)/2008” (the “Law”) to provide for the exchange of information relating to tax matters between Cyprus and other countries with which Cyprus has signed double tax treaties and the conditions under which such exchange can take place.

The main provisions of the Law are the following:

(a) All confidentiality privileges other than the legal privilege can be disregarded subject to the satisfaction of the conditions of the Law.

(b) The requesting state should provide the Cyprus Commissioner of Inland Revenue Department (the “Commissioner”) with specific details of the reason for the request of information.

(c) The information is not provided if the requesting State does not have corresponding enabling provisions for the provision of information in its local legislation.

(d) If the conditions in paragraphs (b) - (c) above are satisfied the Commissioner can obtain information from sources in Cyprus for the purpose of relaying same to the requesting foreign authority.

(e) Notwithstanding any other provisions or conditions set out above, the powers of the Commissioner are exercised only after the written consent of the Attorney General of the Republic has been expressly obtained on a case by case basis.

It is noted that the conditions set out in the Law described above should also be adhered to in the case of a request for exchange of information under the Cyprus Russia Double Tax Treaty , as amended by the Protocol.