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

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
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article

Compliance with Global Minimum Tax Rules in the First Years – Application of the Transitional CbCR Safe Harbour Rules

S.B. Law
Bulletin for international taxation
Taxation and Legal Issues
article

Compliance with Global Minimum Tax Rules in the First Years – Application of the Transitional CbCR Safe Harbour Rules

S.B. Law
article en

Abstract

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.

Bulletin for international taxationVol. 79(6/7)
Openalex Percentile: Top 74%
Taxation and Legal Issues
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Compliance with Global Minimum Tax Rules in the First Years – Application of the Transitional CbCR Safe Harbour Rules — S.B. Law · Bulletin for international taxation (2025) | TGRS Research Map | TGRS