{{item.videoDuration}}
{{item.title}}
{{item.text}}
{{item.videoDuration}}
{{item.text}}
What happened?
On 5 January 2026, the OECD released additional Pillar Two Administrative Guidance on the Global Anti-Base Erosion (GloBE) Model Rules, which includes a Simplified Effective Tax Rate (ETR) Safe Harbour. The Simplified ETR Safe Harbour is intended to provide multinational enterprise (MNE) groups with a more practical way to demonstrate that no Top-Up Tax is due in a jurisdiction. The measure is designed to reduce compliance and administrative burdens by allowing MNEs to use financial accounting data and simplified computations rather than the full GloBE Rules.
Why is it relevant?
This safe harbour is intended to replace the Transitional Country-by-Country Reporting (CbCR) Safe Harbour, which was scheduled to expire for fiscal years beginning on or after 31 December 2026, but has been extended for one additional year. The Simplified ETR Safe Harbour forms part of the ongoing Administrative Guidance under the GloBE Model Rules and should be reflected in local Qualified Domestic Minimum Top-up Tax (QDMTT) legislation. It is also expected to serve as a basis for further potential simplifications to the GloBE Rules.
Actions to consider
Even where initial scoping and transitional safe-harbour analysis have been completed, the simplified ETR safe harbour will require fresh modelling of jurisdiction-by-jurisdiction outcomes and reassessment of where full GloBE computations remain necessary. Key actions include mapping current data-collection processes, reviewing jurisdictional ETR outcomes under the approach, and identifying systems or controls that may need enhancement.
PwC's Tax Policy Bulletin
Pillar Two Simplified ETR Safe Harbour
{{filterContent.facetedTitle}}
{{contentList.loadingText}}
{{contentList.loadingText}}
Contact us
Follow PwC Ireland
Menu