Global Minimum Tax: RSM Ebner Stolz Transitional CbCR Safe Harbour Quick Check as first assesment of the need for action

As of 2024, large corporate groups have to assess for the first time the extent to which a topup tax is payable due to the requirements of the global minimum tax (Pillar II). In this context, even if all group entities are resident in jurisdictions with a nominal corporate tax rate far above the minimum tax rate of 15 %, the issue of the global minimum tax is not settled. However, temporary simplifications might be applicable. Our tool-based approach with the RSM Ebner Stolz Transitional CbCR Safe Harbour Quick Check provides an initial assessment.