Transitional CbCR Safe Harbour Engine
Assess Transitional CbCR Safe Harbour eligibility by Tested Jurisdiction using CbCR + financial statement inputs (including key OECD administrative guidance adjustments).
Assess Transitional CbCR Safe Harbour eligibility by Tested Jurisdiction using CbCR + financial statement inputs (including key OECD administrative guidance adjustments).
On January 5, 2026, the OECD Released Guidance on amendments to the Pillar 2 rules for the Side-by-Side Tax Package. This includes a new Simplified ETR Safe Harbour from December 31, 2026 (December 31, 2025 in certain cases). We provide an excel overview for the key elements of the Safe Harbour calculation.
On January 5, 2026, the OECD Released Guidance on amendments to the Pillar 2 rules for the Side-by-Side Tax Package. This includes a new Substance-based Tax Incentive Safe Harbour. This online tool shows how the new safe harbour operates.
Members have access to our Pillar Two AI-powered Analysis Tool. This is a custom AI model trained on Pillar Two data from our members-only content including our Pillar Two Navigator and Jurisdictional analysis.
For fiscal years that begin on or before 31 December 2025 but not ending after 30 June 2027, the OECD Administrative Guidance includes a simplified formula to allocate CFC taxes in blended CFC regime. Use our simple calculator.
Calculate estimated GloBE top-up tax. Add unlimited companies and jurisdictions via an easy to use control panel to view potential jurisdictional liabilities.
Our Modelling Tool takes the underlying source data from the OECD aggregated CbC source data and subjects it to a data manipulation process to provide a drill down into some of the key metrics and data sources that are relevant for Pillar Two on a jurisdictional basis.
Use our members Income Inclusion Rule Calculator to see how the IIR applies. Enter details of the low-taxed entity including jurisdictional GloBE income and other relevant information to determine top-up tax payable by the parent company.
Our Global Digital Services Tax Tracker has been updated to January 23, 2023.
Last Updated: 08/02/2024 Full Citations to Domestic Laws Links to Domestic Legislation Covers DSTs, Digital Withholding Taxes and Digital PEs Overview How to Use the
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