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Cyprus Banks Advocate For Streamlined Supplementary Tax Declaration Process

Simplified Declarations For Exempt Entities

The Association of Cyprus Banks (ACB) has called for a simplification of the declaration process under the supplementary tax regime. The ACB’s submission, part of a public consultation on amending the Administrative Cooperation in Taxation Law from 2012 to 2025, emphasizes reducing the administrative burden on companies that ultimately incur no additional tax under the new rules.

Targeted Relief For De Minimis And Multinational Entities

ACB’s comments underscore the need to tailor the declaration process for companies exempt under the de minimis rule and for multinational groups in the early stages of international operations. According to the association, if a company qualifies for exemptions that result in a zero top-up tax, the declaration should be adapted to recognize such cases, thereby eliminating unnecessary fields and significantly reducing the compliance workload.

Clarifications On DAC9 And Submission Protocols

In addition to advocating for simplified declarations, the association has requested further clarifications regarding the draft declaration annexed to the bill. Key issues include the method for submitting supplementary tax information, whether special tools or software will be required, and if manual submission remains an option. The ACB stressed the importance of timely notifications and provided guidance from the Cyprus Tax Department to help taxpayers adjust to any new technical requirements.

Enhancing Cross-Border Transparency

Another area of concern is the process for Cypriot groups to notify local tax authorities about foreign entities expecting to receive information through exchange channels. The association seeks confirmation on how the Cypriot parent entity can indicate that its foreign subsidiaries fall under the de minimis exemption. By clarifying these points before the implementation deadline, companies will have sufficient time to make the necessary adjustments.

Transposition Of The EU Directive And Broader Implications

The revised bill aims to transpose EU Directive 2025/872 (DAC9) into national law. In line with the new EU mandates, DAC9 introduces standardized reporting for the automatic exchange of top-up tax information, targeting a uniform declaration process across member states. With a June 30, 2026 deadline for the first top-up tax submission and an automatic exchange starting December 31, 2026, the directive also expands reporting obligations for financial institutions including banks, investment firms, fund managers, and insurance companies.

The directive and the accompanying national legislation represent a significant step toward enhanced transparency and streamlined compliance for multinational enterprises and large domestic groups. With all EU member states required to implement DAC9 by December 31, 2025, and effective from January 1, 2026, stakeholders are urged to prepare for the impending changes in the regulatory landscape.

Copyright Law Struggles To Keep Up With AI Training

Courts Are Still Applying Old Copyright Rules To AI

AI companies train models on enormous amounts of published material, including books, articles and academic research. Whether using that content without authors’ permission violates copyright law remains unresolved.

Much of the debate centres on fair use, which allows copyrighted material to be used without permission in certain circumstances. Courts consider factors such as the purpose of the use, how much material was involved and its impact on the original market.

Anthropic Case Sets An Important Precedent

A major case involving Anthropic and a group of authors provided one of the clearest rulings so far. Judge William Alsup found that using copyrighted books to train AI models was lawful, comparing the process to people reading and studying literature before creating something new.

Anthropic was nevertheless ordered to pay $1.5 billion in a settlement. The penalty concerned books the company had obtained from illegal online libraries rather than the AI training itself.

For AI companies, that distinction could prove significant because it separates studying copyrighted material from directly copying it.

Competition Could Be The Key Issue

A case involving Thomson Reuters and Ross Intelligence offers a different perspective. A court ruled that Ross could not claim fair use after using Reuters’ copyrighted material to develop a competing AI-powered legal research platform.

The decision suggests courts may be less willing to consider AI training fair use when copyrighted content is used to build a product that directly competes with the original.

For authors, an unresolved question is whether AI-generated content should be considered competition for the works used to train these models.

The Law Has Yet To Catch Up

US copyright law predates generative AI by decades, leaving courts to apply old principles to new technology. Questions also remain over copyright protection for AI-generated works. In Thaler v. Perlmutter, a court ruled that material created entirely by AI cannot receive copyright protection.

Major AI companies remain involved in copyright litigation, and different courts could reach different conclusions. For now, there is no universal rule: the legality of AI training will depend on the circumstances of each case and how courts ultimately interpret copyright and fair use.

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