OECD Guidance Includes Details of the Simplified Calculation Safe Harbour for NMCEs

The December 2022 Safe Harbour and Penalty Relief Guidance provided for a Simplified Calculations Safe Harbour. The aim being to reduce or simplify the number of computations and adjustments an MNE is required to make under the GloBE Rules.

The only simplified calculations that have currently been developed by the OECD are the Non-Material Constituent Entity (NMCE) Simplified Calculations.

A number of jurisdictions already include the Simplified Calculations Safe Harbour in their GloBE legislation (see our Pillar Two GloBE Guides), including:

– Austria

– Bulgaria

– Germany

– Ireland

– Luxembourg

– Romania

– UK

The December 2023 OECD Administrative Guidance provides further information on the NMCE Simplified Calculations (for the Simplified Calculations Safe Harbour).