Cyprus consents to the Pillar Two QDMTT and the transitional UTPR Safe Harbours

On 30 October 2023, the government of Cyprus released a press release announcing its consent to the design and application of the transitional Undertaxed Profits Rule (UTPR) Safe Harbour and the permanent Qualified Domestic Minimum Top-up Tax (QDMTT) Safe Harbour as part of the OECD/G20 Inclusive Framework.

The Article 32 of the EU Council Directive 2022/2523 on 14 December 2022 proposes a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the EU, also referred to as “Pillar 2”. The proposed bill establishes a framework for imposing a minimum effective tax rate of 15%.

In June 2023, the government in Cyprus declared that it agreed to the design and application of the transitional Country-by-Country (CbyC) Reporting Safe Harbor that the OECD/G20 Inclusive Framework agreed to as part of the GloBE Implementation.

On 10 October 2023, the Ministry of Finance introduced the bill entitled “Ensuring a Global Minimum Level of Taxation of Multinational Enterprise Groups and Large-Scale Domestic Groups in the Union Act of 2023” and presented the bill for public consultation. The public consultation ended on 31 October, 2023.

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