It is reminded that the reference interest rate is considered to be the higher of the 10-year government bond yield of Cyprus or of the country in which the assets financed by the new equity are utilized, plus 3%. The rate to be used is the one as at 31 December of the tax year preceding the tax year of assessment. So the minimum reference interest rate to be used for the tax year 2019 is 5,302% being the 2,302% yield on the 10-year government bond of Cyprus plus 3%, as provided by the relevant legislation.

It is also reminded that capitalization of existing liabilities, including back to back arrangements, obtained by a Cyprus company qualifies for the purposes of the notional interest deduction.