Transitional Safe Harbors (CbCR and PCbCR)
Focusing on tax transparency to support your compliance
Existing BEPS Action 13 Country-by-Country Reporting (CbCR) plays an important role in Pillar Two through the CbCR transitional safe harbor (TSH) which many groups are expected to rely on. There are natural overlaps and synergies between aspects of Pillar Two, CbCR and the EU Public Country-by-Country Reporting (PCbCR).
The PCbCR directive impacts multinational enterprise (MNE) groups operating in the EU, regardless of headquarter location, as long as certain thresholds are met. The adoption represents a shift of tax transparency obligations from non-public (i.e., BEPS Action 13) or voluntary (i.e., Global Reporting Initiative-207 Tax) to both public and mandatory.
