Transitional CbCR Safe Harbour Calculator

What this tool does

Figures are aggregated by jurisdiction and fiscal year, which reflects the jurisdictional blending the safe harbour requires, then tested against each of the three transitional tests. A jurisdiction qualifies if it satisfies any one of them.

• De minimis test. Total revenue below €10 million and profit (loss) before income tax below €1 million for the jurisdiction, taken from the Qualified CbC Report for the single year. The three-year averaging in the permanent de minimis exclusion under Article 5.5 does not apply here.
• Simplified ETR test. Simplified covered taxes divided by profit (loss) before income tax, measured against the transition rate for the year.
• Routine profits test. Profit (loss) before income tax equal to or less than the substance-based income exclusion computed at the transitional Article 9.2 rates.

Transition rates applied

Transitional period

The safe harbour originally applied to fiscal years beginning on or before 31 December 2026 and not ending after 30 June 2028. The OECD Side-by-Side Package released on 5 January 2026 extended the period by one year, to fiscal years beginning on or before 31 December 2027 and not ending after 30 June 2029, with the transition rate set at 17 per cent for fiscal years beginning in 2026 and 2027.

The Australian position has not yet caught up. The ATO guidance on the transitional CbC reporting safe harbour, current to 30 June 2026, still states the original period. This tool computes fiscal year 2027 on the extended OECD basis and marks those rows, because whether the extension is available to an Australian-parented or Australian-taxed group depends on the Australian rules being updated. Confirm the position before relying on a 2027 result.

Simplifications you need to know about

• Employee costs and PP&E from the CbC report are used as proxies for eligible payroll costs and the eligible tangible asset carrying values that the substance-based income exclusion actually requires. These are not the same measures.
• Income tax accrued for the current year is used without the adjustments the safe harbour requires, being the removal of taxes that are not Covered Taxes and amounts relating to uncertain tax positions. The test proper uses income tax expense per the Qualified Financial Statements.
• The safe harbour is only available where the group has a Qualified CbC Report prepared from Qualified Financial Statements. This tool cannot verify that condition, and no calculation here establishes it.
• The once out, always out rule is not modelled. A jurisdiction for which the group did not apply the safe harbour in the previous fiscal year is generally excluded from it in later years.
• Joint ventures, stateless constituent entities, investment entities, flow-through ultimate parent entities, minority-owned constituent entities and jurisdictions with an eligible distribution tax system are out of scope, as are the specific exclusions in the rules.
• Thresholds are expressed in euro. Converting a report presented in another currency is your responsibility.

Sources

• OECD, Safe Harbours and Penalty Relief: Global Anti-Base Erosion Rules (Pillar Two) (Inclusive Framework on BEPS, December 2022).
• OECD, Tax Challenges Arising from the Digitalisation of the Economy: Global Anti-Base Erosion Model Rules (Pillar Two) (December 2021) art 9.2.
• OECD, Side-by-Side Package (Inclusive Framework on BEPS, 5 January 2026), extending the transitional CbCR safe harbour by one year.
• Taxation (Multinational—Global and Domestic Minimum Tax) Rules 2024 (Cth) ch 8; Taxation (Multinational—Global and Domestic Minimum Tax) Act 2024 (Cth).
• Australian Taxation Office, Transitional CBC reporting safe harbour (web guidance, current to 30 June 2026).