The MTCA notifies that on 29 May 2026 the European Commission has published a frequently asked question which clarifies that all EU Member States should treat Cyprus as having a qualified IIR in effect. MNEs should adopt this position in the top-up tax information return which is due in implementing jurisdictions to be filed by 30 June 2026.

 It should be noted that given that Malta has elected for the delayed application of the IIR and UTPR in terms of Article 50 of the directive, the top-up tax information return cannot be filed in Malta and ultimate parent entities of in scope MNE groups which are situated in Malta must nominate a designated filing entity in another Member State or a third country as had been clarified in the Guidance Note published by the MTCA.