OpenChainGraph Suite · ART-456 · Pillar Two / GloBE
GloBE Transitional Safe Harbour Test Evaluator
Evaluates a jurisdiction against the OECD Pillar Two Transitional CbCR Safe Harbour: the de minimis test (revenue and profit thresholds), the simplified ETR test (simplified covered taxes over profit vs. the fiscal-year transition rate), and the routine profits test (profit vs. substance-based income exclusion). Safe harbour is met if any one of the three tests passes; the jurisdiction's top-up tax is then deemed zero. Each test returns its own gated pass/fail verdict with reasoning.
🔒 All inputs are processed locally in your browser. No data is transmitted. Do not enter real personal data — use synthetic or anonymised inputs only.
⚠ This tool implements the OECD Dec-2022 Agreed Administrative Guidance on the Transitional CbCR Safe Harbour (thresholds and transition rates below). Administrative Guidance updates periodically — verify the current version before relying on a result for a live filing. Elections, DTA characterization, and the SBIE amount itself are your own judgment calls, entered as inputs; this tool performs the threshold arithmetic only and does not recompute SBIE (see ART-455).