The provision
Cyprus names the rate and the day, not just the currency.
Article 230 of the VAT Directive lets an invoice be expressed in any currency provided the VAT payable is expressed in the member state's own currency. Member states transpose that sentence in very different ways. Ireland states only the tax half, in a regulation. France restates the Directive almost word for word in the Act itself. Italy makes it a rounding rule. Germany and the Netherlands say nothing at all about the currency of the document.
Cyprus states all four things - the permission, the euro tax line, the rate, and the day it attaches to - in one paragraph. Regulation 12(4) of the VAT (General) Regulations was replaced in its entirety by article 6(c) of K.D.P. 446/2013, and as replaced it provides that amounts shown on invoices may be expressed in any currency, provided the amount of VAT owed is expressed in euro; and where that amount is expressed in another currency, it is converted into euro, for the purpose of computing the dutiable value, at the rate published by the European Central Bank for the relevant day.
Why the ECB rate is safe wherever you are. The second subparagraph of article 91(2) of the Directive, inserted by Directive 2010/45/EU, says member states shall accept the use of the latest exchange rate published by the European Central Bank at the time the tax becomes chargeable. It is an obligation on the state, not an option for the taxpayer: no member state may refuse the ECB rate. A member state may, however, require you to notify it that you are using that option, and whether Cyprus does is not something we have read.
The storey underneath
The Law beneath that regulation still converts into Cyprus pounds.
This is the part no summary carries, and it is the reason this page cites the regulation rather than the Act. The VAT Law itself, N. 95(I)/2000, has its own conversion rule for working out the value of a supply, and it was never redenominated when Cyprus adopted the euro on 1 January 2008.
«... οποιοδήποτε ποσό σχετικό με τον καθορισμό της αξίας της συναλλαγής είναι εκφρασμένο σε νόμισμα άλλο από την Κυπριακή λίρα, τότε ... το ποσό αυτό μετατρέπεται σε Κυπριακές λίρες λαμβάνοντας υπόψη την ισοτιμία του νομίσματος αυτού προς την κυπριακή λίρα, κατά τη σχετική ημέρα, σύμφωνα με την εκάστοτε σε ισχύ τελωνειακή νομοθεσία.»
Where any amount relevant to determining the value of the transaction is expressed in a currency other than the Cyprus pound, it is converted into Cyprus pounds at that currency's rate against the Cyprus pound on the relevant day, in accordance with the customs legislation in force from time to time.
Fourth Schedule, Part I, para. 8(1) - VAT Law N. 95(I)/2000, consolidated text
Two paragraphs further on, in the same schedule, the rule for goods acquired from another member state was modernised: it says "a currency other than euro" and it names the European Central Bank. One schedule, two paragraphs, two currencies - one of which stopped existing eighteen years ago.
What that means in practice, said carefully
- It is not the rule for the currency on your document. Paragraph 8 governs the value of a supply under articles 14 and 14A. What your invoice must say is delegated by the Tenth Schedule to the Regulations, and that is where regulation 12(4) sits.
- It is not a quirk of the currency rule. Pound amounts survive elsewhere in the same consolidated text, including penalties expressed in pounds. The text is broadly un-redenominated rather than specifically stale here.
When it reaches you
If you sell through the stores, this bites in exactly one case.
Article 230 constrains "the amount of VAT payable or to be adjusted". An app developer's ordinary invoice to a store or an ad network carries no VAT amount at all - it is a reverse-charge supply to another member state, or a supply outside the scope entirely. Where there is no tax line, there is nothing for the currency rule to bind.
The rule reaches you on a domestic supply: an invoice that actually charges Cypriot VAT. That is the case where the amount has to be in euro, and where the day's ECB rate is the number a reviewer would recompute.
What Ureta does about it
The rate is pinned when the month is, and it is kept with the document.
- The authority follows the tenant, not the codebase. A Cypriot entity converts at the ECB rate: the rate the Cypriot regulation names, and the one article 91(2) obliges every member state to accept.
- The rate is pinned per month and stored, so a document that was issued last March still reports the rate it carried in March rather than a number recomputed today.
- Nothing is guessed. Where no rate from a defensible authority is available for a currency, the engine refuses to issue rather than putting a plausible wrong number on a legal document. You can always type the number yourself.
How this page was read
Every sentence above came from the text, and here is which text and when.
This is the part that decides whether a page like this is worth anything. Rates are a commodity; a reading is not.
You sold. The rest is handled.
Ureta is income-reporting software for app creators. It fetches every store and ad network, converts at the rate your own authority names, and has the month's documents ready before the deadline.
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