On 27 October 2026, the Cyprus Tax Department issued an official announcement regarding the enactment of legislation implementing the OECD/G20 Pillar Two Global Minimum Tax (GMT) rules. The law, aligned with EU Directive 2022/2523, establishes a 15% minimum effective tax rate for constituent entities of multinational enterprise (MNE) groups and large-scale domestic groups with annual revenues exceeding €750 million. The rules apply to fiscal years starting on or after 31 December 2023, with the first reporting obligations due for the 2024 fiscal year. The announcement clarifies the scope of covered entities, the calculation of the GloBE income and covered taxes, and the filing requirements for the GloBE Information Return (GIR) via the Tax For All portal.
Key Takeaways
- Scope & Threshold: Applies to MNE groups and domestic groups with consolidated revenue ≥ €750 million in at least two of the four preceding fiscal years.
- Top-up Tax Mechanism: Where the effective tax rate in a jurisdiction is below 15%, a top-up tax is imposed to bring the rate to the minimum.
- Compliance Timeline: First GloBE Information Returns for FY2024 are due by 30 June 2026 (or later per local transposition); Cyprus entities must register and file via TFA.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement