Malta’s tax authority has advised multinational enterprise groups to treat Cyprus as having a qualified Income Inclusion Rule (IIR) under the EU Pillar Two Global Minimum Tax Directive, following European Commission guidance published on 29 May 2026, ahead of top-up tax information return filing deadlines on 30 June 2026.
The Malta Tax and Customs Administration (MTCA) has notified taxpayers that the European Commission published a frequently asked question on 29 May 2026, clarifying that all EU Member States should treat Cyprus as having a qualified Income Inclusion Rule (IIR) in effect under the EU Pillar Two Global Minimum Tax Directive.
According to the MTCA, multinational enterprise (MNE) groups should reflect this position in the top-up tax information return required in implementing jurisdictions, with filings due by 30 June 2026.
The authority also noted that Malta has elected for the delayed application of the IIR and Undertaxed Profits Rule (UTPR) under Article 50 of the directive. As a result, the top-up tax information return cannot be filed in Malta.
The MTCA said that ultimate parent entities of in-scope MNE groups situated in Malta must nominate a designated filing entity in another EU Member State or a third country. The requirement had previously been clarified in a Guidance Note published by the MTCA.
