New: Pillar Two Workflow - generate GIR/GloBE, safe harbour and evidence workflows in one workspace.
Open Workflow Beta
On June 26, 2026, Cyprus issued Decree No. 272/2026 which lists additional OECD/G20 Inclusive Framework materials issued after the enactment of the Cyprus Pillar Two law in December 2024, including the January 2025 Administrative Guidance, the January 2025 GloBE Information Return, the 2025 Consolidated Commentary, the 2025 Examples, and the January 2026 Side-by-Side package.
Law 151(I)/2024 is Cyprus’s domestic implementation of the EU Pillar Two Directive, Council Directive (EU) 2022/2523.
The Cyprus law adopts an OECD-guidance-based interpretive model. Article 2 defines ‘OECD Guidelines’ by listing the core OECD Pillar Two materials already published at the time the law was enacted, including the 2022 Commentary, 2022 Examples, the 2022 Safe Harbours and Penalty Relief document, the 2023 Administrative Guidance, the 2023 GIR, the 2023 Consolidated Commentary, and the June 2024 Administrative Guidance. The definition also includes later OECD documents, provided they are specified by decree of the Minister under Article 60.
Article 59 then states Cyprus is to use the OECD Guidelines as a source of examples or interpretation, to the extent this is not inconsistent with the EU Directive or the Cyprus law.
Article 60 allows the Minister of Finance to issue decrees, published in the Official Gazette, specifying the procedural and technical manner of applying the law and identifying additional later OECD documents for Pillar Two purposes.
Decree No. 272/2026 lists the following OECD materials:
| OECD material added by the decree | Practical significance |
|---|---|
| Administrative Guidance on Article 9.1 of the GloBE Model Rules, published 15 January 2025 | Relevant to transition-year and pre-regime attribute issues. |
| Administrative Guidance on Articles 8.1.4 and 8.1.5, published 15 January 2025 | Relevant to information return mechanics and filing architecture. |
| GloBE Information Return, published 15 January 2025 | Updates the GIR framework to the January 2025 version. |
| 2025 Consolidated Commentary, published 9 May 2025 | Refreshes interpretive guidance incorporated into the Cyprus framework. |
| 2025 GloBE Examples, published 9 May 2025 | Updates worked examples relevant to technical interpretation. |
| OECD Side-by-Side package, published 5 January 2026 | Introduces the new safe harbour architecture and related entry-into-force dates. |
At EU level, the safe harbours agreed on 5 January 2026 were also recorded in the Official Journal of the European Union, which states that all Member States consented to the Simplified ETR Safe Harbour, the extension of the Transitional CbCR Safe Harbour, the Substance-based Tax Incentive Safe Harbour, and the Side-by-Side System.
The key Cyprus dates from Decree No. 272/2026 are as follows:
| Safe harbour | Cyprus decree commencement date |
|---|---|
| Simplified ETR Safe Harbour | Fiscal years starting on or after 31 December 2025 |
| Extension of Transitional CbCR Safe Harbour | Fiscal years starting on or before 31 December 2027, excluding fiscal years ending after 30 June 2029 |
| Substance-based Tax Incentive Safe Harbour | Fiscal years starting on or after 1 January 2026 |
| Side-by-Side Safe Harbour | Fiscal years starting on or after 1 January 2026, or a later year as listed in the OECD Central Record |
| UPE Safe Harbour | Fiscal years starting on or after 1 January 2026 |
The Simplified ETR Safe Harbour date is especially worthwhile noting. The OECD default rule requires implementing jurisdictions to make the safe harbour available for fiscal years beginning on or after 31 December 2026, but permits earlier application for fiscal years beginning on or after 31 December 2025 where the relevant coordination conditions are met. Cyprus appears to have taken up that early-application option in the decree.
If you haven’t got a subscription you can join up below.
This website is not affiliated with or related to the OECD. We provide independent insights and analysis on the OECD Two-Pillar Solution
© 2026 OECDPillars.com
All Rights Reserved