Compliance with Global Minimum Tax Rules in the First Years – Application of the Transitional CbCR Safe Harbour Rules
The global minimum tax, based on OECD GloBE Rules, introduces complex compliance obligations for in-scope MNE groups. This article analyses the Transitional CbCR Safe Harbour, which simplifies initial compliance by carving out low-risk, adequately taxed subsidiaries from more burdensome requirements. It explores key conditions, pitfalls and strategic modelling to assess potential benefits for subsidiaries of MNE groups in global supply chains.
Authors
- S.B. Law
Publication Details
- Journal
- Bulletin for international taxation
- Published
- 2025-07-14
- DOI
- https://doi.org/10.59403/3a2nxqq
- Primary Topic
- Taxation and Legal Issues
- Type
- article
- Field-Weighted Citation Impact
- 0.00