Pillar Two Technical Series: Qualified Country-by-Country Report
April 17, 2025As Pillar Two reporting came into effect for fiscal year 2024 and a number of jurisdictions have implemented regulations, it is critical for relevant multinational enterprises (MNEs) to identify and execute a robust internal process to handle the additional compliance burden. Join us as we cover how MNEs can leverage the Transitional CbCR Safe Harbor (TCSH), given the benefits of a much simpler reporting process and the “once out, always out” rule. We’ll present how relevant MNEs may want to consider whether their current country-by-country reports (CbCRs) are qualified for TCSH and strategies for improving CbCRs to help generate valid and supportable/defendable TCSH results.
Learning Objectives
Upon completion of this program, participants will be able to:
- Discuss OECD guidance on a Pillar Two qualified CbCR.
- Outline common issues in CbCR preparation and whether those would disqualify a CbCR for Pillar Two safe harbor purposes.
- Describe the internal support documentation needed for a relevant MNE group.
Presenters
Jon Morton, Lola Lu