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Resource hub
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.
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Use this as the main reference before diving into topic-specific guides.
Pillar Two and CbCR share the €750m scope, and CbCR data is the backbone of Pillar Two transitional safe harbour testing.
Read the complete guideDeep dives
10 comprehensive guides covering GloBE Rules, charging mechanisms, safe harbours, and CbCR compliance
Pillar Two Guide
Complete overview of OECD GloBE Rules and 15% minimum tax framework
Global Minimum Tax
How the 15% minimum works: ETR calculations, top-up tax, and SBIE
Form 8975 Guide
US CbCR filing: schedules, data sources, and common mistakes
UTPR Guide
Undertaxed Profits Rule: allocation mechanics and implementation
QDMTT Guide
Qualified Domestic Minimum Top-up Tax: design and certification
Income Inclusion Rule (IIR)
Primary charging rule: parent-level collection of top-up tax
Safe Harbours Guide
Transitional CbCR safe harbour and permanent simplifications
EU Public CbCR
Directive 2021/2101 public disclosure requirements and iXBRL
CbCR Risk Assessment
How tax authorities use CbCR data to identify transfer pricing risks
CbCR Preparation Guide
Country-by-Country Report mechanics, thresholds, and filing deadlines
Glossary
Essential Pillar Two and CbCR terminology with definitions and examples
Related resources
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.
See how ArmsLength AI automates benchmarking, generates functional analyses, and creates audit-ready documentation in minutes.