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Master the OECD GloBE Rules and Country-by-Country Reporting. From 15% minimum tax calculations to safe harbours—everything you need for global tax compliance.
The complete guide—your foundation for all deep-dive topics
Pillar Two and CbCR share the €750m scope, and CbCR data is the backbone of Pillar Two transitional safe harbour testing.
10 comprehensive guides covering GloBE Rules, charging mechanisms, safe harbours, and CbCR compliance
Complete overview of OECD GloBE Rules and 15% minimum tax framework
20 min read
How the 15% minimum works: ETR calculations, top-up tax, and SBIE
15 min read
US CbCR filing: schedules, data sources, and common mistakes
16 min read
Undertaxed Profits Rule: allocation mechanics and implementation
13 min read
Qualified Domestic Minimum Top-up Tax: design and certification
13 min read
Primary charging rule: parent-level collection of top-up tax
12 min read
Transitional CbCR safe harbour and permanent simplifications
15 min read
Directive 2021/2101 public disclosure requirements and iXBRL
15 min read
How tax authorities use CbCR data to identify transfer pricing risks
12 min read
Country-by-Country Report mechanics, thresholds, and filing deadlines
18 min read
Essential Pillar Two and CbCR terminology with definitions and examples
Pillar Two compliance connects to broader transfer pricing documentation
Master File, Local File, and CbCR form the three-tier documentation structure. Pillar Two adds new data requirements on top of these foundations.
CbCR data feeds into Pillar Two safe harbour tests. Understanding benchmarking helps interpret CbCR ratios and ETR outliers.