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, which transposes the EU Pillar Two Directive into Cypriot law.
A practical issue arose because Cyprus does not appear in the OECD central record of jurisdictions with transitional qualifying status. The European Commission addressed this in its FAQ on Cyprus IIR treatment 2024. The Commission states that, for purposes of the EU Pillar Two Directive, Cyprus’ qualified IIR status is derived from Article 3(18) of the Directive for fiscal years commencing on or after 31 December 2023. It also states that Cyprus can receive top-up tax information returns as of 31 May 2026 and is obliged under EU law to exchange information under DAC9 in time for the first exchange deadline.
The filing route is the Tax For All (TFA) portal. All Pillar Two notifications, filings and returns are submitted through TFA, either directly by the constituent entity or by an authorised representative, provided there is an active TFA account. The relevant forms have been published on TFA and on the Cyprus Tax Department website, with explanatory guides available on the TFA website.
Therefore, the Cyprus submission route should be treated as open for the first-year Pillar Two TTIR/GIR-equivalent filings and notifications. Note that the specific forms and submission screens sit behind the TFA login and taxpayer profile permissions. Before a deadline exercise, MNEs should verify the TFA profile, representative mandate, CY Login arrangements, entity TINs and access to the relevant Pillar Two forms.
The public support route includes the Tax For All Pillar II page in English. The Tax Department’s public Pillar II hub is available at the Cyprus Tax Department Pillar II page.
The issued Cyprus Pillar Two compliance set currently issued comprises Forms T.D.331 2026 to T.D.336 2026. The table below summarises their function and key timing points.
| Form | Function | Who typically files | Core timing / practical point |
|---|---|---|---|
| T.D.331 2026 | Article 45 notification identifying the entity filing the TTIR and its jurisdiction. | A Cypriot constituent entity, where the TTIR is filed by the UPE or designated filing entity in another relevant jurisdiction. | Due on the TTIR notification timetable: within 18 months from the last day of the reporting fiscal year for the transition year, or by 30 June 2026, whichever is later. |
| T.D.332 2026 | Article 47 constituent entity notification. | A Cypriot constituent entity, unless a designated local entity makes the relevant group notification. | Should be analysed with the group’s central filing election, Cyprus entity status and any changes in scope or group membership. |
| T.D.333 2026 | Article 45 notification by a designated local entity. | A Cypriot designated local entity filing on behalf of all relevant Cypriot constituent entities. | Used as the group filing alternative to entity-by-entity Article 45 notifications. |
| T.D.334 2026 | Article 47 group notification by a designated local entity. | A Cypriot designated local entity. | Used where a designated local entity fulfils Article 47 notification obligations for the Cypriot group population. |
| T.D.335 2026 | IIR Top-Up Tax Due Return. | A Cypriot parent entity with an IIR return obligation. | Due within 30 days after the TTIR filing deadline. Any IIR top-up tax due must be paid within the same period. Public summaries state that the return is required even where no top-up tax is payable. |
| T.D.336 2026 | Top-Up Tax Information Return (TTIR), corresponding to the GIR for Cyprus purposes. | The UPE, designated filing entity, each Cypriot constituent entity, or a Cypriot designated local entity, depending on the filing architecture. | Due within 18 months from the end of the reporting fiscal year, or by 30 June 2026, whichever is later, for the first reporting cycle. |
The content of the Cyprus TTIR is identical, subject to certain confirmations, to the TTIR template included in DAC9 and to be filed through TFA. For XML and schema work, groups should also consider the OECD GloBE Information Return XML Schema, while checking the Cyprus/TFA instructions for any domestic upload, validation or confirmation requirements.
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