Cyprus Issues Guidance on Filing for the Global Minimum Tax

The Cyprus Tax Department issued guidelines regarding the local implementation of the Pillar 2 Global Minimum Tax (Law 151(I)/2024), detailing the filing and notification deadlines for Cypriot constituent entities for the first year 2023-2024, including guidelines on filing the GloBE Information Return.

Constituent entities established in Cyprus, in EU Member States and/or in third countries (hereinafeter referred to as the “Group”) shall submit the Top-Up Tax Information Return (Form TD336 (2026)) (TTIR), if the ultimate parent entity or the designated submitting entity of the Group is established in Cyprus.

Within 18 months from the last day of the reporting financial year or June 30, 2026, whichever date is later:

– Each Cypriot constituent entity of the Group must notify the Tax Department of the identity of the entity submitting the TTIR, as well as the jurisdiction in which it is established, through the Notification Filed by a Constituent Entity (Form TD331 (2026)).

– In the event that the TTIR is submitted by a “designated local entity”, it shall be submitted only by the said designated local entity on behalf of all Cypriot constituent entities.

A Cypriot parent entity of the Group that owes additional tax shall submit the of Additional Tax Return (“Form TD335) 2026”) within 30 days from the due date for submission of the Additional Tax Information Return and pay the additional tax within this period.

The Cypriot parent constituent entity of the Group that owes additional tax may also submit a revised TTIR (“Form TD335) 2026”):

– within 18 months from the end of the financial year,

– until June 30, 2026, or

– within thirty (30) days from the date of submission of the revised TTIR,

and pay additional tax within 30 days from the due date for submission of the TTIR.

If any of the abovementioned returns or due tax tax are submitted or paid before September 30, 2026, no administrative fines        and/or interest and/or charges will be imposed.

Guidelines on the local implementation of the Pillar 2 Global Minimum Tax