Safe Harbour Quick Check

Test whether a jurisdiction qualifies for transitional CbCR safe harbour relief under the GloBE rules. Enter your data below to assess all three qualifying tests instantly.

Jurisdiction name

1. De Minimis Test

The jurisdiction is excluded from GloBE calculations if current-year total CbCR revenue is below EUR 10 million and current-year profit (loss) before income tax is below EUR 1 million (or is a loss). These figures come from the Qualified CbC Report for the fiscal year being tested.

Total CbCR Revenue (current year), EUR From the Qualified CbC Report for this fiscal year

Profit (Loss) before Income Tax (current year), EUR From the Qualified CbC Report for this fiscal year

2. Simplified ETR Test

The jurisdiction qualifies if the simplified ETR (income tax expense divided by profit before tax) meets or exceeds the applicable transition rate for the fiscal year. The OECD transition rates are: 15% for fiscal years beginning in 2023 or 2024, 16% for 2025, and 17% for 2026 or 2027. Uncertain tax positions should be eliminated from the income tax expense figure.

Fiscal year start Calendar year in which the fiscal year begins

Profit (Loss) before Income Tax, EUR

Income Tax Expense, EUR After eliminating uncertain tax positions

3. Routine Profits Test

The jurisdiction qualifies if profit before income tax is equal to or less than the substance-based income exclusion (SBIE) amount, calculated from payroll and tangible asset carve-outs.

Profit (Loss) before Income Tax, EUR

Substance-Based Income Exclusion (SBIE), EUR

About the Transitional CbCR Safe Harbour

The OECD Inclusive Framework introduced the transitional CbCR safe harbour to reduce compliance costs during the initial years of the GloBE rules. It allows multinational groups to set the top-up tax to zero in a jurisdiction if the jurisdiction satisfies any one of three quantitative tests, using data from qualifying Country-by-Country Reports.

The three tests are applied on a jurisdiction-by-jurisdiction basis. A jurisdiction only needs to pass one of the three tests to qualify for safe harbour relief in a given fiscal year. This tool provides a quick indication based on the figures you enter, but the actual determination depends on the precise application of the Administrative Guidance, including data sourcing and adjustment rules.

The transitional safe harbour is available for fiscal years beginning on or before 31 December 2027, and is scheduled to expire after this transition period. Groups should plan for the eventual need to perform full GloBE calculations in all jurisdictions.

Disclaimer: This tool is provided for informational purposes only and does not constitute tax advice. Results are indicative and should be verified against the full GloBE rules and applicable Administrative Guidance. For a comprehensive safe harbour assessment across all your jurisdictions, book a demo of the Pillar2 platform.

Need to assess safe harbour across all your jurisdictions?

The Pillar2 platform automates transitional CbCR safe harbour testing for your entire group, with full audit trail and multi-year tracking.

Book a demo Learn about Safe Harbour Assessment