Compliance with Global Minimum Tax Rules in the First Years – Application of the Transitional CbCR Safe Harbour Rules

The global minimum tax, based on OECD GloBE Rules, introduces complex compliance obligations for in-scope MNE groups. This article analyses the Transitional CbCR Safe Harbour, which simplifies initial compliance by carving out low-risk, adequately taxed subsidiaries from more burdensome requirements. It explores key conditions, pitfalls and strategic modelling to assess potential benefits for subsidiaries of MNE groups in global supply chains.