Cyprus has issued detailed guidance on the implementation of Pillar Two under Law 151(I)/2024, clarifying filing obligations, centralised reporting options, and notification procedures for multinational enterprise groups. The rules set out deadlines for the 2023–2024 reporting period, including the submission of the Top-Up Tax Information Return and related forms, while also confirming relief measures and penalty-free filing conditions in certain cases.
The Cyprus Department of Taxation has issued guidance on implementation deadlines for Law 151(I)/2024 on 15 June 2026, which enforces the OECD’s global minimum taxation framework across Cyprus.
The directive addresses Cypriot constituent entities and joint ventures within multinational enterprise groups for the first reporting period spanning 31 December 2023 to 31 December 2024.
Central filing and discharge of obligations
MNE groups may elect centralised filing under Article 45(3) of the Law, allowing the ultimate parent or designated filing entity to submit the Top-Up Tax Information Return (Form T.D.336) 2026 in Cyprus.
When this occurs, other Cypriot group members are relieved of individual filing duties. Groups that filed centrally through an EU Member State or OECD-listed third country—per the list published on 18 May 2026—similarly discharge Cyprus-based entities’ obligations.
Cypriot constituents must still notify the Tax Department of the filing entity’s identity and jurisdiction using Form T.D.331, unless a designated local entity handles the notification via Form T.D.333.
Notifications, deadlines, and payment
All constituent entities and joint ventures must file the Constituent Entity Notification (Form T.D.332) or, if designated local, the Designated Local Entity Group Notification (Form T.D.334). These submissions are due within 18 months from the fiscal year’s close or by 30 June 2026, whichever falls later.
The parent entity liable for top-up tax must submit the Income Inclusion Rule Return (Form T.D.335) within 30 days of the TTIR deadline, with payment due 30 days after TTIR filing. Revised returns may be filed under Article 50(1) for both the TTIR and IIR, provided deadlines are met.
Alternatives and relief
Groups declining central filing must have each constituent entity file the TTIR individually, unless a designated local entity acts on their behalf. Revised filings are permitted under the same deadlines.
A grace period applies: if obligations mature before 30 September 2026, no administrative penalties, interest, or charges will be imposed, provided submission and payment occur by 30 September 2026.
All filings and notifications proceed through the Tax For All system.
