Cyprus has tabled a Pillar Two amendment bill to introduce a qualified domestic minimum top-up tax for financial years beginning from 31 December 2025.
Cyprus has opened a public consultation on amendments to its Pillar Two legislation intended to address observations from the European Commission and align the domestic rules more closely with OECD guidance. The consultation opened on 30 July 2026 and is scheduled to close on 5 September 2026.
On June 26, 2026, Cyprus issued Decree 272/2026 to confirm entry-into-force dates for the main January 2026 OECD safe harbour package
On June 15, 2026, the Cyprus Tax Department issued two announcements on the domestic implementation of the Pillar Two framework. The first concerned the European Commission’s position on Cyprus’ Income Inclusion Rule (IIR). The second addressed filing deadlines and compliance obligations for Cypriot constituent entities and joint ventures under Law 151(I)/2024.
On December 18, 2024, Cyprus published the law to implement the EU Minimum Tax Directive its its Official Gazette. This implements the IIR from December 31, 2023 and a UTPR and domestic minimum tax from December 31, 2024.
On 12 December 2024, the Cyprus House of Representatives voted to approve local legislation to implement Pillar 2. The Law will come into effect once it is published in the official Government Gazette.
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