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Pillar Two: Safe Harbours

On December 20, 2022, the OECD issued the Safe Harbours and Penalty Relief: Global Anti-Base Erosion Rules (Pillar Two), which includes details of two safe harbours and penalty relief for the Pillar Two GloBE rules. 
 
 The three published reliefs were the:
 
 
Note that the first two are temporary, whereas the Simplified Calculations Safe Harbours are permanent.
 
On July 17, 2023, the OECD issued its Second Set of Administrative Guidance. This included a QDMTT Safe Harbour and a Transitional UTPR Safe Harbour.
 
Whilst the safe harbours/harbors represent a significant simplification for MNEs, qualifying for a safe harbour for a jurisdiction does not exempt an MNE Group from complying with group-wide GloBE requirements such as the requirement to prepare and file its GloBE Information Return. 
 
For information on the domestic implementation of the Safe Harbours, see our GloBE Country Guides. 
 
Picture of Lee Hadnum
Lee Hadnum
Lee is a qualified Chartered Accountant and a former Senior Tax Analyst at Bloomberg Tax. Lee began his career in Ernst & Young's Entrepreneurial Services department and has 20 years of international tax planning experience.

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