Pillar Two

What Is Due In Cyprus

• The Cyprus domestic top-up tax applies from fiscal years beginning 31 December 2024 — so 2025 — where the jurisdictional effective rate is below 15%; the substance carve-out reduces the profit that is topped up (✓ L.151(I)/2024 s.12, ✓ Dir. art. 28; L.151(I)/2024 s.54). The income inclusion rule applies from years beginning 31 December 2023 (✓ L.151(I)/2024 s.61).
• The top-up tax information return (T.D.336) for 2025 is due 31 Mar 2027, 15 months after the year end (✓ L.151(I)/2024 s.45(7)). The GloBE notification — or, once made, any change to it — is due by the same date (✓ L.151(I)/2024 s.47). Within 30 days, by 30 Apr 2027, each Cyprus entity owing top-up tax under the income inclusion rule, the UTPR or the Cyprus domestic top-up tax files the top-up tax return and pays (✓ L.151(I)/2024 s.45(7)). For the first years — fiscal years beginning 31/12/2023–30/12/2024 — the Tax Department says a parent entity located in Cyprus files that return even when the top-up tax is nil (✓ L.151(I)/2024 s.45(7)); Aegean Crest Shipping's ultimate parent is outside Cyprus (MH), so whether any Cyprus company files a nil return as an intermediate parent is to be confirmed by the practice. The information return may be filed centrally by the group elsewhere, with only a notification in Cyprus (✓ L.151(I)/2024 s.45(7)).
• 2024, the transitional year (✓ L.151(I)/2024 s.57): the information return and the notification were due by 30 Jun 2026, the top-up tax return and payment by 30 Jul 2026. Filings and payments for fiscal years beginning 31/12/2023–30/12/2024 that fell due before 30 November 2026 carry no fines, interest or charges if made by 30 November 2026 — 23 days from today (✓ Pillar II FAQ: 30 Nov 2026).
• Fines on the information return are not imposed for fiscal years beginning on or before 31 December 2026 (but not a year ending after 30 June 2028) where the group shows it acted in good faith to understand and apply the law (✓ L.151(I)/2024 s.49(12)).
• Every transfer pricing adjustment moves the minimum tax: the arm's length figure is the one the computation uses (✓ Dir. art. 16(4)). No adjustment is open on this engagement.

The Shipping Exclusion, Flow By Flow

International shipping income, and qualified ancillary income up to half of it, come out of the computation — with their costs — but only where the strategic or commercial management of the ships is effectively carried on from the jurisdiction (✓ Dir. art. 17 / s.18, ✓ Dir. art. 17(4): 50%). For the Cyprus companies the test turns on where the ships are managed from — likely the same Limassol facts as tax residence (✓ ITL s.2), to be confirmed by the practice. The law says nothing of tonnage tax: income outside the exclusion carries almost no covered tax and may attract the top-up (Tonnage tax and Pillar Two · to be confirmed by the practice).

Suggestion Gross amounts, before the cost allocation the rules require. Ancillary €3,980,000 against shipping €47,700,000 in Cyprus: 8.34%, inside the 50% cap.