Executive summary

On 15 June 2026, the Cyprus Tax Department (CTD) issued an announcement clarifying the operation of the central filing mechanism, applicable notification requirements and compliance deadlines for the first reporting fiscal year under the Cyprus Pillar Two legislation (Law 151(I)/2024). As part of the announcement, the CTD waived the imposition of administrative penalties for certain filings and payments due by 30 September 2026.

This development is expected to reduce duplicative reporting obligations and align Cyprus with the Organisation for Economic Co-operation and Development (OECD) administrative framework for Pillar Two compliance.

Cyprus is a signatory to the OECD Multilateral Competent Authority Agreement (MCAA), which facilitates the central filing and automatic exchange of Global Anti-Base Erosion (GloBE) Information Returns (GIRs) between participating jurisdictions. Cyprus is also expected to transpose DAC9, which is the European Union (EU) Directive on Administrative Cooperation) enabling central filing of a Top-Up Tax Information Return (TTIR) with EU Member States.

Note that a recent FAQ issued on Pillar Two Directive clarified that: all EU Member States should treat Cyprus as having a qualified IIR in effect; Cyprus can receive top-up tax information returns as of 31 May 2026; and Cyprus is committed and obliged under EU law to exchange information under DAC9 with other Member States in time for the first exchange deadline. If an MNE opts to file its top-up tax information return centrally in Cyprus, other Member States should not require domestic filing at that time in line with DAC9.

Main points covered by the announcement

Multinational Enterprise (MNE) Groups

The CTD has clarified that MNE Groups within the scope of the Cyprus Pillar Two Law may elect to use the Central Filing Mechanism provided under Article 45(3) of the Cyprus Pillar Two legislation (the Law) for fiscal years beginning between 31 December 2023 to 31 December 2024.

Central filing — key points

MNE Groups may submit the Top-Up Tax Information Return (Form T.D.336) (TTIR) in Cyprus if the Ultimate Parent Entity (UPE) or the Designated Filing Entity is located in Cyprus. In such a case, the filing obligation of all other Cypriot Constituent Entities is deemed fulfilled. The TTIR corresponds to the GIR contemplated under the OECD framework.

Alternatively, if the TTIR is submitted in another EU Member State, or a third country (excluding Turkey) that is included in the OECD Common Understanding list dated 18 May 2026, the filing obligation of Cypriot Constituent Entities for a TTIR is deemed fulfilled, provided the relevant notification requirement is met. (For background, see EY Global Tax Alert, OECD releases common understanding on GIR central filing and updates to Administrative Guidance under Pillar Two, dated 20 May 2026.)

The CTD also clarifies that if an MNE Group does not elect for the Central Filing Mechanism, either:

• Each Cypriot Constituent Entity is generally required to submit a TTIR in Cyprus
• A Designated Local Entity may be appointed to file the TTIR on behalf of all Cypriot Constituent Entities

Revised TTIRs may also be submitted in accordance with Article 50(1)(a) of the Law.

Relevant filings and deadlines

Top-Up Tax Information Return (Form T.D. 336)

Form T.D. 336 should be submitted within 18 months from the last day of the reporting fiscal year, or by 30 June 2026 (whichever is later) — i.e., 30 June 2026 for financial year ended 31 December 2024.

Revised TTIR

If Cyprus is the filing jurisdiction, the UPE or Designated Filing Entity may submit a revised TTIR that covers all Cypriot Constituent Entities.

If central filing occurs abroad, Cypriot Constituent Entities are relieved from filing a revised TTIR locally.

TTIR notification

If TTIR is submitted in another EU Member State, or a third country:

• Each Cypriot Constituent Entity must notify the CTD, via "Notification Filed by a Constituent Entity" (Form T.D.331), provide the name and Taxpayer Identification Number of the entity that submits the TTIR and provide the name of the jurisdiction in which it is located.
• If a Designated Local Entity in Cyprus files on behalf of all Cypriot Constituent Entities, only the "Notification by a Designated Local Entity" (Form T.D.333) is submitted.

Pillar Two Registration/notification

Each Cypriot Constituent Entity or Joint Venture must file the "Constituent Entity Notification (Form T.D.332)" unless a Designated Local Entity in Cyprus files on behalf of all Cypriot Constituent Entities, only the "Designated Local Entity Group Notification" (Form T.D.334) is submitted.

Entities must notify the Tax Department of any changes regarding previously submitted notifications. Notification is also required if either:

• An entity ceases to be part of the Group
• The MNE Group falls outside the scope of the Law

The relevant forms (Forms T.D. 331, 332, 333 or 334) should be submitted within 18 months from the last day of the reporting fiscal year, or by 30 June 2026 (whichever is later).

IIR Top-Up Tax Payable Return (Form T.D.335)

A Cypriot parent entity liable for top-up tax must submit "Income Inclusion Rule Top-Up Tax Due Return" (Form T.D.335) within 30 days from the TTIR deadline. The return must be submitted even if the tax payable is nil.

Payment of top-up tax must also be made within 30 days of the TTIR deadline.

Revised IIR Return

A revised Form T.D. 335 may be submitted within the latest of:

• 18 months from fiscal year-end
• 30 June 2026
• 30 days from submission of a revised TTIR

In general

All notifications and returns are submitted via the Tax For All (TFA) portal, either by the Constituent Entity or by an authorized representative with an active TFA account.

Non-application of administrative penalties

The CTD announcement further states that if notifications or returns or payments which are due before 30 September 2026 are filed and any TUT due is paid by 30 September 2026, no statutory administrative fines and/or interest and/or surcharges shall be imposed. This, in effect, means that for financial years ended 31 December 2024 for which notifications are due by 30 June 2026 and returns or payments are due by 30 July 2026, no statutory administrative fines, interest or surcharges will be imposed if filing and payment is made by 30 September 2026.

Implications

MNE Groups should determine whether to apply the central filing mechanism and Groups relying on central filing mechanism should ensure notification obligations are still fulfilled in Cyprus.

In addition, Cypriot parent entities subject to IIR should assess relevant filing obligations and payment deadlines.