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Pillar Two Safe Harbors and Penalty Relief

Since multinational entities with revenue above €750 million will now be required to pay a minimum tax of at least 15% and report their Global Anti-Base Erosion (GloBE) effective tax rate (ETR) for the various jurisdictions in which they operate, the OECD has created two safe harbors and a system for penalty relief to help ease the compliance burden.

This OnPoint outlines the Pillar Two safe harbors and penalty relief provisions, specifically:

  • A temporary CbCR Safe Harbor
  • A permanent framework for a potential Simplified Calculations Safe Harbor
  • Temporary Penalty Relief

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