Cyprus Pillar Two: the first-year returns and notifications are due by 30 November 2026

Cyprus companies in a group with consolidated revenue of EUR 750 million or more must file their first Pillar Two returns and notifications, for fiscal years starting between 31 December 2023 and 30 December 2024, by 30 November 2026. The Tax Commissioner set that date on 27 October 2026. Any top-up tax is paid by then too.

For a calendar-year group, that first fiscal year is 2024. Under the Cyprus global minimum tax law, Law 151(I)/2024, the first filings were due on 30 June 2026 and the first payments a month later. In June the Tax Department said it would not charge penalties, interest or surcharges on anything filed and paid by 30 September 2026. On 27 October it went further: by decision of the Tax Commissioner, the last date for every first-year return, notification and payment is now 30 November 2026, and nothing filed or paid by then will attract penalties, interest or charges.

The date matters to more Cyprus companies than the headline suggests. Most Cyprus entities in large groups will owe no Cyprus top-up tax for 2024. Many of them still have a form to file.

Which Cyprus companies are caught by Pillar Two?

The law applies to Cyprus "constituent entities" of groups whose consolidated revenue is EUR 750 million or more. That covers:

• Cyprus subsidiaries of foreign multinational groups: holding, finance, trading, shipping-related and service companies that sit inside a large international group.
• Cyprus parent entities of in-scope groups, whether the ultimate parent or an intermediate one.
• Large-scale domestic groups, where every entity is in Cyprus. The Department's announcement applies the same filing rules to them.

Below the threshold, none of this applies. That is most Cyprus businesses, and it is why our articles on the 15% corporate tax rate and the IP Box treat Pillar Two as a question for large groups only.

Why do most in-scope companies owe nothing in Cyprus for 2024, yet still have to file?

Because Cyprus brought its rules in in stages. For fiscal years starting on or after 31 December 2023, Cyprus applies only the Income Inclusion Rule (IIR): a Cyprus parent entity pays top-up tax on low-taxed profits of its subsidiaries elsewhere. The domestic top-up tax on low-taxed profits in Cyprus itself, and the undertaxed profits rule, start a year later, for fiscal years starting on or after 31 December 2024.

So for 2024, a Cyprus company that is not a parent of anything usually has no Cyprus top-up tax to pay. But the filing duties do not depend on owing tax. Every Cyprus constituent entity has to tell the Department who it is and who files the group's information return, and the Cyprus parent that applies the IIR has to file its return even if the tax due is nil.

Which form does a Cyprus company file?

The forms are the Department's 2026 series, filed in the Tax For All (TFA) system. Which ones you file depends on where the group files its main information return, the Top-Up Tax Information Return (TTIR):

The "qualifying third countries" are those on the OECD list of 18 May 2026 for central filing of the GloBE information return for the 2024 reporting year. If the group's TTIR goes to one of them, or to another EU member state, the Cyprus companies do not file a T.D.336 of their own; they file the notifications.

A Cyprus subsidiary of a foreign group will typically file a T.D.331 and a T.D.332, or rely on one designated Cyprus entity to file T.D.333 and T.D.334 for all of them.

What exactly changed on 27 October?

The Department's wording is that 30 November 2026 "is the last date". This is the second relief on the same first-year filings.

The decision covers only the first fiscal year (starting 31 December 2023 to 30 December 2024). It says nothing about 2025 returns, which follow the normal 15-month timetable.

What should a Cyprus company in a large group do this month?

1. Ask the group's tax team where the 2024 TTIR was, or will be, filed, and by which entity. That one answer decides which Cyprus forms you need.
2. Check whether a designated local entity has been appointed for Cyprus. If so, one entity files T.D.333 and T.D.334 for all; if not, each Cyprus company files its own T.D.331 and T.D.332.
3. If you are a Cyprus parent entity, file the T.D.335 even if the IIR top-up tax is nil, and pay any top-up tax by 30 November.
4. Make sure the person filing has an active TFA account, either the company's own or an authorised representative's. Pillar Two forms are filed only in TFA.
5. Look ahead to 2025. From fiscal years starting on or after 31 December 2024, the Cyprus domestic top-up tax applies, so a Cyprus entity with an effective rate below 15% may owe top-up tax in Cyprus itself. Our effective tax rate tool is a first check; the GloBE calculation is a separate, longer exercise.

30 November 2026 is also the last date for several other Cyprus filings this year, including the 2024 company tax return (TD4) and the 2025 employer's return (TD7). They are all in our Cyprus tax calendar 2026.

The short version

• Who: Cyprus companies in groups with consolidated revenue of EUR 750 million or more, including large domestic groups.
• What: the first-year Pillar Two filings, forms T.D.331 to T.D.336, and payment of any IIR top-up tax.
• For: fiscal years starting 31 December 2023 to 30 December 2024 (2024 for a calendar-year group).
• By: 30 November 2026, the Tax Commissioner's decision of 27 October 2026. No penalties, interest or charges if done by then.
• Where: Tax For All only.

This article is general information on Cyprus tax rules, not advice on your position. If your group has Cyprus entities and you are not sure which forms they file, talk to our corporate tax team.