Safe Harbour Assessment
Automatically evaluate each jurisdiction against the OECD's transitional CbCR safe harbour tests. Eliminate unnecessary GloBE calculations for qualifying jurisdictions and focus your compliance resources where they matter.
Automated Three-Limb Testing
The transitional CbCR safe harbour allows multinationals to set their top-up tax to zero in jurisdictions that satisfy any one of three quantitative tests. Pillar Fifteen applies all three tests simultaneously across every jurisdiction in your group, so you never miss a qualifying exemption.
- De minimis test: automatically checks whether current-year total CbCR revenue falls below EUR 10 million and current-year profit (loss) before income tax falls below EUR 1 million (or is a loss)
- Simplified ETR test: divides simplified covered taxes by profit before tax and compares the result to the applicable transition rate for the fiscal year
- Routine profits test: determines whether total profit is equal to or less than the substance-based income exclusion amount computed from payroll and tangible asset carve-outs
- Handles fiscal year alignment and transition rate schedules automatically
| Jurisdiction | De minimis | Routine profits | Simplified ETR | Status |
|---|---|---|---|---|
| United Kingdom | ✓ | 21.4% | Pass | |
| South Africa | ✓ | 18.2% | Pass | |
| Mauritius | ✓ | 12.8% | Pass | |
| Singapore | ✓ | 16.9% | Pass | |
| Netherlands | 14.1% | Fail | ||
| Bermuda | 0.0% | Fail |
Jurisdiction-by-Jurisdiction Dashboard
Your group might operate in dozens of jurisdictions, but not all of them require the full weight of a GloBE computation. Pillar Fifteen gives you a single view that shows the safe harbour status of every jurisdiction at a glance, so you can immediately see where you stand.
- Clear pass or fail indicators for each jurisdiction with drill-down to the specific test that qualified
- Instantly identify which jurisdictions must proceed to a full GloBE ETR and top-up tax calculation
- Filter and sort by region, entity count, revenue materiality, or test outcome
- Export results for board reporting or external adviser review
- ✓22 jurisdictions qualify under safe harbour
- !4 jurisdictions require full GloBE computation
- ?1 jurisdiction missing CbCR data
- ·27 jurisdictions tested
Built on Your Existing CbCR Data
The safe harbour was designed by the OECD to leverage data groups already prepare for country-by-country reporting. Pillar Fifteen works the same way. If your CbCR data is ready, your safe harbour assessment is ready, with no incremental data collection, no new reporting burden for local teams.
- Imports directly from your existing CbCR submissions or group reporting packages
- Applies the required adjustments to move from CbCR figures to the simplified covered taxes measure
- Year-on-year tracking as the transitional safe harbour period progresses toward its scheduled expiry
- Flags jurisdictions approaching threshold boundaries so you can plan ahead for future periods
- ✓CbCR FY24 imported
- ✓Adjusted to simplified covered taxes
- ✓Cross-validated to consolidated accounts
- !Mauritius routine profits margin near threshold
- ✓Year-on-year tracking enabled
Stop over-calculating. Start with safe harbour.
Most multinationals can eliminate full GloBE calculations in a significant number of jurisdictions. See how many of yours qualify.