T475 · Tax / GloBE · AINumbers.co

Pillar Two Safe Harbour Checker

Assess eligibility for three OECD transitional CbCR safe harbours (December 2022 agreed guidance) and the permanent SBIE / routine-profits safe harbour. The transitional safe harbours: de minimis, simplified ETR, and routine profits: are available for FY2024, FY2025, and FY2026. Where a jurisdiction qualifies, no top-up tax computation is required for that period (GloBE Model Rules Art. 8 / agreed guidance). ⚠ The safe harbour rules contain many conditions not captured by this tool; verify against the full agreed guidance before relying on results in a filing.

OECD Pillar Two · Dec 2022 agreed guidance Transitional safe harbours De minimis · Simplified ETR · Routine profits US-HQ: IIR/UTPR exempt (Jan 2026) FY2024–FY2026 transition period
⚠ US Headquarter Exemption: US-HQ groups are exempt from IIR and UTPR per the OECD January 2026 side-by-side package. Safe harbour analysis is still relevant for QDMTT exposure (which applies to all groups) and for informing GIR disclosures. Verify the current scope of the US exemption at oecd.org.
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Group & period

Transitional safe harbours expire after FY2026.

Jurisdiction data (from CbCR / GloBE)

Use country-by-country report (CbCR) data for the transitional tests. Revenue, PBT, and covered taxes are per the local CbCR template. Simplified ETR threshold varies by year (2024: 15%, 2025: 15%, 2026: 16%, 2027+: 17%).

JurisdictionCbCR revenue (m)CbCR PBT (m)CbCR covered taxes (m)GloBE ETR %SBIE amount (m)

Safe Harbour Eligibility

Sources: OECD agreed guidance on transitional CbCR safe harbours (December 2022); OECD GloBE Model Rules Art. 8 (permanent safe harbour: substance-based income); OECD Administrative Guidance (2023–2024). Simplified ETR thresholds: 15% (2024–2025), 16% (2026), 17% (2027+) per agreed guidance table. ⚠ These thresholds and tests are subject to updates: verify against current OECD guidance before relying on results. GIR disclosure: qualifying jurisdictions must still be included; safe harbour only removes top-up tax obligation.