Ebner Stolz Transitional CbCR Safe Harbour Quick Check
From 2024, large corporations will have to assess for the first time the extent to which an additional tax is payable due to the requirements of the global minimum tax in case they are not subject to taxation at an effective minimum tax rate of 15 %. The discussion draft on the German implementation law of the Minimum Tax Directive provides for temporary relief using CbCR data. The Ebner Stolz Transitional CbCR Safe Harbour Quick Check offers an initial assessment.
In concrete terms, this tool-based approach can be used to check, on the basis of existing CbCR data, enriched with certain additional information, which tax jurisdictions fall under the Safe Harbour rules and therefore no tax increase amount could be applied for group companies resident there in the first years of application.
Further information regarding the Ebner Stolz Transitional CbCR Safe Harbour Quick Check can be found here.
Note: What is the current procedural status of the implementation of the global minimum tax in Germany? We have compiled this for you here.