2026 · MNE Group Tool
5 questions to determine whether your group is in scope of Cyprus Pillar Two and which mechanic applies — IIR, UTPR, or QDMTT.
Cyprus transposed the EU Pillar Two Directive (2022/2523) effective 1 January 2024 for fiscal years starting then. This quiz determines whether your group is in scope and which mechanic — IIR, UTPR, or QDMTT — likely applies.
1. Does your group have consolidated revenue of €750 million or more in at least 2 of the past 4 fiscal years?
This is the Pillar Two scope threshold. If no, you're out of scope entirely.
2. Is the Ultimate Parent Entity (UPE) of the group resident in Cyprus?
If yes, Cyprus IIR applies primarily.
3. Does the group have a Cyprus intermediate parent or partially-owned parent that is in scope of IIR?
Affects whether Cyprus IIR applies before another jurisdiction's IIR.
4. Does the group have constituent entities in jurisdictions with effective tax rates below 15%?
If no, top-up tax is zero — but you still need to compute and report.
5. Does Cyprus-resident operations have an effective tax rate below 15% (after considering NID, IP Box, and transitional adjustments)?
If yes, Cyprus QDMTT applies before any foreign IIR/UTPR.
Answer the questions on the left. The verdict updates live and routes you to the right next step.
This quiz is a routing aid based on the published rules of EU Directive 2022/2523 and Cyprus's transposing legislation. Pillar Two computations (IIR top-up, GloBE ETR by jurisdiction, QDMTT) require detailed group financial data and are an ICPAC-coordinated engagement.
GloBE ETR by jurisdiction, IIR/UTPR/QDMTT cascade, GIR preparation, and QDMTT payment timing — coordinated by ICPAC-registered tax advisers.
Free consultation · No obligation · Reply within 2 hours