Cyprus: New Public CbC Reporting Obligation

The Cyprus Department of the Registrar of Companies and Intellectual Property has announced the commencement of the submission of the Declaration of Corporate Income Tax Information for companies falling within the scope of Law 138(I)/2024.

This new reporting requirement forms part of Cyprus’ implementation of EU Directive (EU) 2021/2101, introducing Public Country-by-Country Reporting (Public CbCR) for certain large multinational groups.

What is Public Country-by-Country Reporting?

Public Country-by-Country Reporting is a transparency initiative requiring qualifying multinational enterprises to publicly disclose key income tax information on a jurisdiction-by-jurisdiction basis.

The objective is to enhance corporate tax transparency by allowing stakeholders, investors and the public to better understand where multinational groups generate profits and where they pay corporate income tax.

Which entities are affected?

The reporting obligation generally applies to:

• Ultimate parent companies of multinational enterprise groups; and
• Certain standalone undertakings,

where the total consolidated revenue exceeds €750 million in each of the last two consecutive financial years.

In certain circumstances, the reporting obligations may also extend to Cyprus subsidiaries or branches of multinational groups whose ultimate parent company is established outside the European Union.

For the vast majority of Cyprus companies and SMEs, this obligation does not apply.

Information to be disclosed

Entities within the scope of the legislation will be required to submit and publicly disclose, among other information:

• Total revenues;
• Profit or loss before income tax;
• Income tax accrued;
• Income tax paid;
• Number of employees; and
• Accumulated earnings,

presented separately for each relevant tax jurisdiction.

Submission through the Registrar of Companies

The Department of the Registrar of Companies and Intellectual Property has activated the electronic submission process for the filing of the Declaration of Corporate Income Tax Information in accordance with Law 138(I)/2024.

Affected entities should ensure that the required information is prepared accurately and submitted within the applicable statutory deadlines using the Registrar’s electronic platform. The Registrar has also published guidance and technical instructions regarding the filing procedure.

What should companies do now?

Companies should assess whether they fall within the scope of Law 138(I)/2024 by considering:

• Whether they are members of a multinational group;
• Whether the group’s consolidated revenue exceeds the €750 million threshold;
• Whether any Cyprus reporting obligations arise for local subsidiaries or branches.

Early assessment is recommended, as preparation may require coordination between multiple group entities and the collection of financial information from several jurisdictions.

How we can assist

Our Corporate Tax and Compliance team can assist with:

• Determining whether your group falls within the scope of Law 138(I)/2024;
• Assessing the reporting obligations of Cyprus companies and branches;
• Reviewing the required disclosures;
• Preparing the Public Country-by-Country Report; and
• Managing the electronic submission with the Registrar of Companies.

If you believe your group may be affected, please contact us to discuss your reporting obligations and ensure timely compliance.