Skip to main content
Looking up at a cluster of skyscrapers converging into a blue sky with clouds.

Pillar Two Technical Series: Qualified Country-by-Country Report

April 17, 2025

As 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

Headshot Image for Lola Lu
Lola Lu

Senior Manager, International Tax

Forvis Mazars US

Like what you see?
Subscribe to receive tailored insights directly to your inbox.