Pillar Two Transitional CbCR Safe Harbour Modelling Tool

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. 

One of the key safe harbours is the Transitional CbCR Safe Harbour.

• revenue and income below the de minimis threshold (the de minimis test); 
• an ETR that equals or exceeds an agreed rate (the ETR test); or 
• no excess profits after excluding routine profits (the routine profits test).

Our members-only modelling tool carries out the calculations based on the required inputted information to determine whether this safe harbour applies. 

You can read more about the safe harbours at: OECD Releases the Safe Harbours for the Pillar Two GloBE Rules.