The tax authorities have issued guidance on compliance obligations under the Global Minimum Tax framework, as implemented through Law 151(I)/2024, covering multinational and large domestic groups for financial years beginning between 31 December 2023 and 31 December 2024.
The tax authorities confirm that a Group of Multinational Enterprises (MNEs) that falls within the scope of the above law, with constituent entities established in Cyprus, European Union Member States, and/or third countries (hereinafter, the “Group”), may choose the “central filing mechanism” provided for in article 45(3) of the Law.
Furthermore, with respect to any financial year commencing between 31 December 2023 and 31 December 2024 the following conditions:
| 1. | To submit the Top-Up Tax Information Return (TTIR) (Form T.D.336) to Cyprus, if the ultimate parent entity or the designated submitting entity of the Group, as the case may be, is established in Cyprus. In such a case, the obligation of the other Cypriot component entities of the Group to submit the TTIR (Form T.D.336) is exhausted. |
| 2. | In the event that the TTIR is submitted in a European Member State or in third countries included in the list issued by the OECD on 18 May 2026, in accordance with the Global Minimum Tax: Support for Central GloBE Information Return Filing and Exchange (2024 Reporting Fiscal Year), the obligation of the Cypriot component entities of the Group is exhausted, regarding the submission of the TTIR (Form T.D.336). |
As recently approved by the EU, Multinational groups with Cypriot entities may use a “central filing mechanism,” allowing a single entity — typically the parent or designated filer — to submit the TTIR. Where such central filing is completed in Cyprus or in an eligible foreign jurisdiction, local Cypriot entities are generally relieved from separate filing obligations.
Key compliance deadlines require filings and notifications to be submitted within 18 months of the financial year-end or by 30 June 2026, whichever is later. Entities must notify authorities of the filing entity and report group structure details and update any changes promptly.
Cypriot parent entities must also submit and pay any top-up tax due under the Income Inclusion Rule within 30 days of the TTIR deadline, even where no tax liability arises. Revised filings are permitted under specified conditions.
For groups that do not opt for central filing, each Cypriot entity must submit its own TTIR unless a designated local entity is appointed to act on behalf of the group.
Importantly, the tax authorities confirmed that no penalties, interest, or charges will apply for submissions or payments due before 30 September 2026, provided they are completed by that date. All filings are to be made through the Tax For All (TFA) system.
A copy of the announcement of 15 June 2026 is on the government website here (in Greek only).
Andreas Papagavriel, Partner at Baker Tilly comments “The guidance and returns issued by the Tax Authorities in Cyprus confirms a pragmatic and internationally aligned approach to Pillar Two compliance in Cyprus, significantly reducing duplicative reporting through centralised TTIR filing, while the temporary waiver of penalties until 30 September 2026 provides important transitional relief for affected groups. ”
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