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LEGAL BRIEFING · CORPORATE TRANSPARENCY · INTERNATIONAL TAX
Public Country-by-Country Tax Reporting in Cyprus: Which Groups Must File?
Cyprus has moved public country-by-country reporting from an EU directive into company law. The question for a Cyprus entity is not simply whether it has a large local business, but whether it sits within a group whose public disclosure obligations have reached Cyprus.
Grigoris Aivazidis · Lawyer and International Tax Adviser · Legal Briefing · 10 September 2026
Public country-by-country tax reporting in Cyprus is now a statutory corporate-disclosure regime, introduced through sections 157A to 157IΔ of the Companies Law. It requires qualifying groups to make defined income-tax information public and can draw Cyprus subsidiaries and branches of non-EU groups into the filing process.
The regime follows Directive (EU) 2021/2101, but its practical effect is determined by the Cyprus Companies Law. It should not be confused with confidential country-by-country reporting submitted to tax authorities. This is a public statement, placed with the Registrar and made freely available on a website.
For multinational groups, the issue is no longer only whether data can be produced. It is who is legally responsible for ensuring that the right data is produced, lodged, published and retained in Cyprus.
This Is Public Corporate Disclosure, Not Ordinary Tax Reporting
The statutory report is described in the Companies Law as a statement of income-tax information. It is a company-law transparency obligation. Its audience is not limited to the Tax Department. Investors, counterparties, journalists, employees and the public may read it.
The disclosure is narrower in some respects than a confidential OECD-style country-by-country report, but that does not make it less consequential. It places revenue, pre-tax profit or loss, current income tax, tax paid in cash, employee numbers and accumulated earnings into a public framework. The required territorial presentation can also make a group’s commercial story appear very different from the way the same figures are understood internally.
The authoritative Cyprus rules are in sections 157A to 157IΔ of the Companies Law. The right starting point is therefore a legal scope analysis, not a last-minute extraction from a group reporting package.
The €750 Million Test
The principal threshold is not a Cyprus turnover test. A Cyprus-incorporated ultimate parent undertaking, or a Cyprus standalone undertaking, is within the core regime where its revenue exceeds €750 million in each of the two consecutive financial years relevant to the test.
The two-year condition matters. A group should not make the assessment from one annual figure, a management forecast or a local entity’s revenue. The legislation looks to the revenue presented in the consolidated financial statements for an ultimate parent, or the annual financial statements for a standalone undertaking.
There are important limits. A group whose operations, including branches, are confined to one Member State is outside this core obligation. Certain credit institutions and investment firms already subject to equivalent public reporting can also fall outside it. These exceptions should be tested against the statute, rather than assumed from the group’s sector or EU presence.
When a Cyprus Subsidiary of a Non-EU Group Must Publish
A Cyprus company can be brought into the regime because of its parent group, even though the Cyprus company itself does not approach €750 million of revenue. Sections 157Δ and 157ΙΓ are directed at medium-sized and large Cyprus companies whose ultimate parent is not governed by the law of an EU Member State and whose consolidated revenue exceeds the threshold for each of the two preceding financial years.
That Cyprus subsidiary must publish the report concerning its ultimate parent. If the parent does not provide the necessary information after being asked, the subsidiary is not simply released. It must publish the information in its possession, received or acquired, together with a statement explaining that the parent did not make the required information available.
This is the point at which a group reporting problem becomes a Cyprus director problem. A local board needs a documented request, a clear response path and a record of the legal basis on which it concluded that a report, an explanatory statement or no filing is required.
The Non-EU Branch Route and the €8 Million Cyprus Condition
The legislation also addresses non-EU groups operating through a Cyprus branch rather than a Cyprus subsidiary. A branch of a non-EU company can be in scope where its Cyprus net turnover exceeds €8 million in each of the two preceding financial years and the wider group meets the €750 million consolidated-revenue test.
The branch route is not automatic in every structure. It is designed for the situation in which the non-EU group does not have a medium-sized or large subsidiary in an EU Member State that would otherwise carry the publication obligation. The order in which the group map is analysed therefore matters.
For branches, the persons appointed to complete the branch-publicity formalities have statutory responsibility, within the scope of their powers, to ensure the obligation is met as far as they are able to know. That makes corporate-administration arrangements relevant to the compliance analysis.
What the Public Statement Must Show
The statement requires more than a headline tax figure. It identifies the group or standalone undertaking, the financial year and reporting currency. It also covers the nature of activities, full-time-equivalent employees, revenue including related-party revenue, profit or loss before income tax, current income tax accrued, cash income tax paid and accumulated earnings.
Jurisdictional presentation is central. The information is shown separately for each EU Member State and for the relevant jurisdictions on the EU lists of non-cooperative tax jurisdictions. Other jurisdictions are generally presented on an aggregated basis. A group cannot assume that data for a listed jurisdiction may be blended into a broader regional category.
The Companies Law allows a helpful general explanation of material differences between income-tax accrued and cash tax paid. In practice, that narrative can matter as much as the numbers. A public explanation should be technically correct, consistent with the financial statements and intelligible to a reader who does not know the group’s tax history.
Registrar Filing, Website Publication and Retention
The time limit is clear. The statement of income-tax information, or the explanatory statement required in a non-EU subsidiary case, must be delivered to the Registrar of Companies for registration within 12 months of the balance-sheet date for the relevant financial year.
The Registrar records the document without conducting a substantive review. That point should not be misunderstood as reduced responsibility. The statute places collective responsibility on the relevant members of the administrative, management and supervisory body, and an audit report must state whether a report was required for the preceding year and, if so, whether it was published.
The document must also be available free of charge, at least in Greek or English, on the relevant undertaking’s, subsidiary’s or branch’s website within the same 12-month period. It must remain accessible for at least five consecutive years. The Registrar’s electronic registration portal is the practical submission environment, but the legislative deadline and document responsibility should be settled before a portal filing is attempted.
When a Non-EU Parent's Own Report Can Avoid Duplication
A Cyprus subsidiary or branch is not required to duplicate the exercise where the non-EU ultimate parent or standalone undertaking prepares a report that complies with the content rules, makes it freely available in a machine-readable electronic format through its website, uses at least one official EU language and does so within 12 months of the balance-sheet date.
There is a further condition. The parent report must identify the name and registered office of one EU subsidiary, or the name and address of one EU branch, that has filed the report with the relevant Member State register. This is an allocation rule, not a vague group comfort letter.
Before relying on this route, a Cyprus entity should retain the parent report, the published web address, evidence of timing, the designated EU filing entity and a written confirmation that the statutory content has been considered. A report that is similar in substance is not necessarily a report that meets the Cyprus conditions.
Commercial Confidentiality Is Not a General Exemption
The law permits temporary omission of specific information where publication would seriously prejudice the commercial position of the businesses concerned. The omission must be clearly identified and justified in the statement, and the information must be disclosed in a later report within five years.
This is not a general confidentiality election. Information relating to the jurisdictions covered by the relevant EU lists cannot be omitted through this route. Any decision to withhold information should be documented at board level and tested against the actual statutory threshold for serious commercial prejudice.
Commentary by Grigoris Aivazidis
A Practical Compliance Protocol
Groups with a Cyprus presence should complete the following work before their first relevant deadline:
- map the ultimate parent, EU subsidiaries and Cyprus branches
- test the €750 million threshold across the correct two consecutive financial years
- identify whether the Cyprus entity is a parent, standalone undertaking, medium-sized or large subsidiary, or qualifying branch
- determine whether a compliant non-EU parent report and an EU designated filing entity already exist
- prepare a written request for the required parent information where needed
- agree responsibility for Registrar delivery, website publication and five-year retention
- review the statutory auditor’s reporting implications
- create a concise explanatory narrative for material tax differences before the report becomes public
A clean compliance file will be more valuable than an elegant filing made without a documented basis.
Conclusion
Public country-by-country tax reporting in Cyprus does not affect every company with an international shareholder. It does, however, reach far beyond Cyprus ultimate parents. Non-EU groups with the right Cyprus subsidiary or branch profile can be brought into a public reporting process that involves the Registrar, a public website and director-level responsibility.
The deadline is 12 months from the relevant balance-sheet date. The better time to decide scope, request data and allocate filing responsibility is before the financial year closes, not when the report is due.
For a confidential review of a group’s Cyprus reporting position, you may submit a private enquiry to AVZ Law Office.
Legal Notice
This publication provides general legal information and commentary. It is not tax, accounting or legal advice for a particular group, Cyprus company, branch, financial year or filing. Public country-by-country reporting requires a fact-specific assessment of group structure, revenue, entity size, jurisdictional status, statutory exceptions and current filing requirements. Specific advice should be obtained before relying on an exemption, a parent report or a proposed filing route.
Public country-by-country reporting is often described as a tax-transparency measure. That description is correct but incomplete. In Cyprus, its legal machinery sits inside company law. It changes the responsibility of the local corporate body.
The weak response is to ask group finance whether a report exists. The proper response is to determine which entity carries the legal obligation in the EU, whether the Cyprus company falls within the subsidiary or branch routes, and whether the published report satisfies the Cyprus conditions.
The fact that the Registrar records the filing without verifying its substance should concentrate the mind. A public entry is not an official confirmation that the group has complied. It is a public record of what the responsible entity chose to file. For directors, that makes the scope memorandum, information requests, parent confirmations and retention file as important as the final report itself.
In my view, the first reporting cycle should be treated as a governance exercise. It needs tax, accounting, legal and corporate-administration input before the deadline becomes urgent.