Malta Confirms Treatment of Cyprus as Having a Qualified Pillar 2 IIR; Notes GloBE Information Returns Cannot be Filed in Malta

Malta's Tax and Customs Administration has issued a notice confirming that Cyprus should be treated as having a qualified Pillar 2 Income Inclusion Rule (IIR) in effect. The notice further explains that because Malta opted to delay the application of the IIR and the Undertaxed Profit Rule (UTPR), GloBE Information Returns (top-up tax information returns) cannot be filed in Malta.

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Cyprus' IIR treatment under the EU Pillar 2 Global Minimum Tax Directive

The MTCA notifies that on 29 May…