1. Administering Tax Reporting
  2. Working with Pillar Two
  3. Working with Transitional Safe Harbor Rules
  4. Example Tests

Example Tests

De Minimis Test

  • The multi-national company group reports:
    • total revenue of less than EUR 10 million
    • profit (loss) before income tax of less than EUR 1 million
  • Data from CbCR

in such Jurisdiction on its qualified CbC Report for the Fiscal Year (FY)

Simplified ETR Test

  • The multi-national company group has a simplified ETR that is equal to or greater than the transition rate in such jurisdiction for the FY:
    • 15% for FY beginning in 2023 & 2024
    • 16% for FY beginning in 2025
    • 17% for FY beginning in 2026
  • Data from financial statements and CbCR

Routine Profits Test

  • The multi-national company group’s profit (loss) before income tax in such jurisdiction is equal to or less than the substance-based income exclusion amount, for constituent entities resident in that jurisdiction under the CbCR, as calculated under the GloBE Rules
  • Data from CbCR and GloBE computation