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Pillar Two: Safe Harbours

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
 
A fourth safe harbour (the Qualified Domestic Minimum Top-up Tax (QDMTT) safe harbour is to be considered as part of the administrative guidance). The three published reliefs are the:
 
 
Note that the first two are temporary, whereas the Simplified Calculations Safe Harbours are permanent.
 
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. 
 

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