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.

The Transitional CbCR Safe Harbour is a short-term measure that would allow an MNE to avoid undertaking detailed GloBE calculations for a jurisdiction if it can demonstrate, based on its qualifying CbCR and financial accounting data, that in the jurisdiction it has:
  • 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.

Safe Harbour Tool

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