This site uses cookies. and this alert will appear once and then not again.

Unlike the other Pillar Two releases on Tax Certainty and the GloBE Information Return, the rules on safe harbours and penalty relief are not subject to a public consultation process. This release takes the form of an Inclusive Framework approved publication.

Stakeholders in earlier public consultations highlighted the need for safe harbours and simplifications which would reduce the complexity of performing detailed calculations and meeting burdensome compliance obligations under the Pillar Two rules, particularly in the early years of implementation and for low-risk jurisdictions. The Inclusive Framework has attempted to respond to this by designing a transitional CbCR safe harbour, a regulatory framework for the development of a potential permanent safe harbour, as well as a common understanding for a transitional penalty relief regime.

Read more in our Tax Policy Alert.