The Association of Cyprus Banks (ACB) has asked for the declaration process for the supplementary tax to be made simpler.

Their comments were submitted as part of the public consultation on the bill to amend the Administrative Cooperation in Taxation Law of 2012 to 2025.

The association’s comments focus on the need to reduce the administrative burden on companies that ultimately owe no additional tax under the new rules.

“Our main comment is the need or obligation to submit the declaration in a simplified form by companies which fall under exemptions that result in zero additional tax under Pillar 2,” the association said.

It explained that if a company is exempt under the de minimis rule or due to provisions for multinational groups in the early phase of international activity, and ultimately owes no top-up tax, the declaration should be adapted to recognise such cases.

This, it added, would eliminate the need to complete all other fields, significantly reducing compliance workload and simplifying the overall process.

The association also requested a series of clarifications regarding the draft declaration included in the annex of the bill concerning DAC9.

Among them is the method of submission of the supplementary tax information declaration as outlined in the annex, and whether taxpayers will need to use special tools or software for submission or submit the tables manually.

Timely notification, it said, is necessary to allow taxpayers to implement any technical requirements.

The association further called for the issuance of guidance by the Cyprus Tax Department clarifying how to complete the declaration, as well as providing definitions or explanations for fields that are unclear, such as applicable rules and regimes for the purposes of the rules.

It also asked for clarification on how foreign entities of a Cypriot group will be required to notify their local tax authorities that they expect to receive information via exchange from Cyprus, where the Cypriot group files its supplementary tax declarations.

In addition, it sought confirmation of how the Cypriot parent entity will indicate that its foreign subsidiaries fall under the de minimis rule and are therefore exempt from any additional tax.

It stressed that such clarifications must be provided in good time to give taxpayers sufficient opportunity to implement the required changes within the prescribed deadline.

The bill under consultation seeks to transpose the EU Directive 2025/872, known as DAC9, which was adopted by the EU Council on April 14, 2025, and published in the Official Journal of the EU on May 6, 2025.

The directive introduces new rules for the mandatory automatic exchange of information on top-up tax declarations resulting from the application of the global minimum tax, in line with EU Directive 2022/2523 and Cyprus’ 2024 law on ensuring a minimum level of taxation for multinational enterprise groups and large-scale domestic groups.

It establishes a standardised declaration template to be used by all EU countries to ensure uniformity and transparency, and sets a deadline for the first top-up tax submission by June 30, 2026.

The first automatic exchange of information between EU member states must take place by December 31, 2026.

The directive also expands reporting obligations for financial institutions including banks, investment firms, fund managers and insurance companies that offer investment or pension products, requiring them to submit information on their clients’ tax obligations.

EU member states must transpose DAC9 into national law by December 31, 2025, with application starting January 1, 2026.