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
 

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