Tax Department Announcements on Pillar II: Cyprus Filing Obligations & IIR Overview

(i) The first announcement informs of the European Commission’s FAQ (Frequently Asked Question on Pillar 2 Directive - Cyprus IIR treatment 2024) issued on 29 May 2026, based on which Cyprus is considered to have implemented a Qualified Income Inclusion Rule (IIR) for fiscal years commencing on or after 31 December 2023.

Based on the FAQ, as of 31 May 2026, Cyprus is able to receive the Top-Up Tax Information Return and is committed to exchange such information within the required timeframe under DAC9. Where an MNE submits the Top-Up Tax Information Return through the centralised filing mechanism in Cyprus, no separate local filings of the Top-Up Tax Information Return will be required by other EU Member States, in line with the provisions of DAC9.

The relevant announcement can be accessed via the attached link IIR Announcement

(ii) The second announcement provides guidance on the compliance obligations and applicable filing deadlines for Cypriot constituent entities.

The guidance applies to fiscal years commencing between 31 December 2023 and 31 December 2024 and sets out the requirements for the submission of:

• Top-Up Tax Information Return (TTIR)/Globe Information Return
• Notifications
• Income Inclusion Rule (IIR) Top-Up Tax returns
• Payment of any Top-Up Tax due
• Filing Deadlines

The relevant announcement can be accessed via the attached link Pillar II Compliance obligations and filing returns and deadlines

Central Filing Mechanism
MNE Groups may opt for a central filing mechanism, allowing the Top‑Up Tax Information Return (TTIR) to be submitted:

i) in Cyprus (where the UPE or designated entity is located) or

ii) in another qualifying EU/third‑country jurisdiction included in the OECD list issued on 18 May 2026.

Where the central filing mechanism is exercised, Cypriot constituent entities are relieved from local TTIR filing, subject to the submission of the required notifications to the Cyprus Tax Department.

For fiscal years commencing between 31 December 2023 and 31 December 2024, all filings (TTIR and notifications) must be submitted within 18 months from the end of the fiscal year or by 30 June 2026, whichever is later.

Where any filings are due before 30 September 2026, or any Top-Up Tax is payable before that date, no penalties, interest, or surcharges will apply, as long as they are submitted or paid by 30 September 2026.

Cypriot constituent entities must submit notifications identifying the TTIR filing entity and its jurisdiction, provide constituent entity (or designated entity) notifications, and promptly inform the Tax Department of any subsequent changes to the reported information.

The Income Inclusion Rule (IIR) Top‑Up Tax Due Return (Form T.D.335) must be filed within 30 days from the TTIR filing deadline, and any Top‑Up Tax payable must be settled within the same 30‑day period. This obligation applies even where no Top‑Up Tax liability arises.  Payments are made through the Tax For All (TFA) portal.

The framework allows for the submission of revised TTIRs in Cyprus and revised IIR Top‑Up Tax returns, within the prescribed statutory deadlines, including cases where corrections or additional liabilities arise.

Where the central filing mechanism is not elected, each Cypriot constituent entity is required to submit its own TTIR locally, unless a designated Cypriot entity is appointed to file on behalf of all local entities.

The same provisions that apply to MNE Groups not using the central filing mechanism are also applicable to Large Scale Domestic Groups. In such cases, each Cypriot constituent entity is required to submit its own TTIR locally, unless a designated Cypriot entity is appointed to file on behalf of all local entities.

Entities are permitted to file amended TTIRs and IIR Top-up Tax returns within the prescribed statutory time limits, including where adjustments or additional tax liabilities arise.

All returns and notifications must be submitted electronically through the Tax For All (TFA) portal, either directly by the entity or through an authorized representative.

Top-Up Tax Information Return (Form T.D.336): The TTIR is the main Pillar II reporting requirement, providing the information needed to assess a group's global minimum tax position under the GloBE rules. It may be filed centrally by the ultimate parent entity (or a designated filing entity) or locally where no central filing mechanism applies.

Where the ultimate parent entity or designated filing entity is in Cyprus, submission of the TTIR in Cyprus satisfies the filing obligation for all Cypriot constituent entities, eliminating the need for separate local filings.

Considering that the TTIR is filed in another EU Member State or in an eligible third country included in the OECD list issued on 18 May 2026, no additional filing obligation is triggered for the Cypriot constituent entities.

The TTIR must be submitted within 18 months from the end of the financial year or by 30 June 2026, whichever is later.

Form T.D.331 – Notification filed by a Constituent Entity (Article 45): Required by Cypriot constituent entities where the TTIR is filed in another EU Member State or eligible third country. The filing deadline aligns with the TTIR.

Form T.D.332 – Constituent Entity Notification (Article 47): Required by Cypriot constituent entities where the TTIR is filed in Cyprus. It is generally submitted by each Cypriot entity unless a designated local entity files on their behalf. The deadline aligns with the TTIR.

Form T.D.333 – Notification filed by a Designated Local Entity (Article 45): Required by a designated Cypriot entity where the TTIR is filed in another EU Member State or eligible third country to submit the notification on behalf of all Cypriot constituent entities. The deadline aligns with the TTIR.

Form T.D.334 – Designated Local Entity Group Notification (Article 47): Required by a designated local entity where the TTIR is filed in Cyprus to fulfill the notification obligations for all Cypriot constituent entities. The deadline aligns with the TTIR.

Form T.D.335 – IIR Top-Up Tax Due Return:  Required where a Cypriot parent entity is liable for top-up tax under the Income Inclusion Rule (IIR). The return must be filed by the Cypriot parent entity within 30 days after the TTIR deadline, regardless of whether tax is payable, and any tax due must be paid within the same period.

The Cyprus Tax Department has recently issued detailed guidance and the relevant Pillar II compliance forms in relation to the Law for Ensuring a Global Minimum Level of Taxation for Multinational Enterprise Groups and Large-Scale Domestic Groups (Law 151(I)/2024).

The materials have been made available through the Tax Department’s website, and include:

• User guides covering submission and payment procedures, and
• A full set of notifications and tax returns required for compliance.

Access to the guidance, forms and returns can be found here: Tax Department Pillar II