GloBE Rules Series

ITQ G-

158

April 13, 2026

Question

An MNE Group is required to apply an IIR with respect to jurisdiction X.

The group was eligible for, and elected to apply, the Transitional CbCR Safe Harbour for each of 2024 to 2026. The group elects to apply the Simplified ETR Safe Harbour (SESH) in 2027. However, the group is not eligible to apply SESH in 2028 and 2029. The group elects to apply SESH in 2030.

Based on this limited information, what is the Transitional Year for the group for jurisdiction X?

Answer

See section 4.5 of chapter 2 of the Side-by-Side Package.

Para. 128:

“Unlike the Transitional CbCR Safe Harbour, the Simplified ETR Safe Harbour does not delay the Transition Year for a Tested Jurisdiction. The Transition Year for a Tested Jurisdiction is the earlier of the Transition Year otherwise determined under the GloBE Model Rules and Commentary … or the first Fiscal Year that the MNE Group elects to apply the Simplified ETR Safe Harbour for that jurisdiction. … The Transition Year does not reset when an MNE Group re-enters the Simplified ETR Safe Harbour after exiting in a previous Fiscal Year.”

Therefore, in the facts set out in the question, the Transition Year is 2027 (see para. 129).

Do you agree?

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