C1– Safe Harbour Check
Last updated on 2025-07-11
Overview
The Safe Harbour Check workspace includes the three transitional safe harbour tests:
- Simplified ETR test
- De minimis test
- Routine profits tests
These tests are followed by information on the applicability of the transitional safe harbour.
For the safe harbour check, entity data is aggregated on a jurisdictional level based on the reporting dimension type selected for the CbCR-Safe Harbour Blending.
This article contains the following sections:
Navigation
The C1 – Safe Harbour Check workspace can be found at Pillar 2 | Calculation | C1 – Safe Harbour Check. The workspace is displayed as follows, for example:
Performing Safe Harbour Check
Specify the following per section:
Option
Description
1.1
Qualified CbCR Profit (Loss) before Income Tax
Displays the aggregate of the CbCR-2 values for the jurisdiction or subgroup.
1.3
Income Tax Expense (including uncertain tax positions)
Displays the aggregate of the CbCR-3.1 values for the jurisdiction or subgroup.
1.4
Income Tax Expense related to uncertain tax positions
Displays the aggregate of the CbCR-3.2 values for the jurisdiction or subgroup.
1.5
Income Tax Expense (after eliminating uncertain tax positions)
Displays the aggregate income tax expense after eliminating uncertain tax positions, based on the following calculation: {1.3} - {1.4}.
1.6
Simplified ETR
Displays the aggregate simplified ETR by dividing the income tax by the qualified CbCR profit or loss before income tax: {1.5} / {1.1} * 100.
1.7
Transition Rate
Displays the transition rate of 15%.
1.8
Simplified ETR Test successful?
Indicates whether or not the simplified ETR test is successful.
Option
Description
2.1
Qualified CbCR Revenue
Displays the aggregate of the CbCR-1 values for the jurisdiction or subgroup.
2.3
Average GloBE Revenue threshold
Displays the GloBE revenue threshold (€ 10,000,000).
2.4
Qualified CbCR Profit (Loss) before Income Tax
Displays the aggregate of the CbCR-2 values for the jurisdiction or subgroup.
2.6
Average GloBE Income threshold
Displays the fixed GloBE income threshold (€ 1,000,000).
2.7
De Minimis Test successful?
Indicates if the de minimis test is successful.
Option
Description
3.1
Qualified CbCR Profit (Loss) before Income Tax
Displays the aggregate of the CbCR-2 values for the jurisdiction or subgroup.
3.2
Relevant Eligible Payroll Costs of Eligible Employees performing activities in the jurisdiction
Displays the aggregate of the CO-1.1 values for the jurisdiction or subgroup.
3.3
Application of relevant mark-up percentage for the Reporting Fiscal Year
Displays the relevant mark-up percentage for the reporting year, e.g. 9.8% for 2024.
3.4
Payroll Carve-Out Amount
Displays the aggregate amount of eligible payroll costs for the jurisdiction or subgroup multiplied by the relevant mark-up percentage.
3.5a
Carrying value of relevant Eligible Tangible Assets located in the jurisdiction at the beginning of the reporting year
Displays the aggregate of the CO-2.1 values for the jurisdiction or subgroup.
3.5b
Carrying value of relevant Eligible Tangible Assets located in the jurisdiction at the end of the reporting year
Displays the aggregate of the CO-2.2 values for the jurisdiction or subgroup.
3.5
Carrying value of relevant Eligible Tangible Assets located in the jurisdiction
Displays the arithmetic mean of the values in lines 3.5 and 3.5b above.
3.6
Application of relevant mark-up percentage for the Reporting Fiscal Year
Displays the relevant mark-up percentage for the reporting year, e.g. 7.8% for 2024.
3.7
Tangible Assets Carve-Out Amount
Displays the carrying value of relevant eligible tangible assets multiplied by the relevant mark-up percentage.
3.8
Total amount of the Substance-Based Income Exclusion
Displays the sum of the payroll carve-out amount and the tangible assets carve-out amount.
3.9
Routine Profits Test successful?
Indicates whether or not the routine profits test is successful.
Option
Description
4
Transitional CbCR Safe Harbour available for the Fiscal Year?
5
Election to use Transitional CbCR Safe Harbour in the last Fiscal Year?
6
Transitional CbCR Safe Harbour applicable for the Fiscal Year?
Transitional CbCR Safe Harbour is applicable, if
- at least one of the tests in (1.8), (2.7), and (3.9) is successful;
- the CbCR Safe Harbour is available for the reporting fiscal year (4); and
- the group had elected to use the transitional safe harbour in any preceding years when it was available (5).
7
Is the election to use the Transitional CbCR safe harbour exercised for the current year?
8
Result: Will the Transitional CbCR safe harbour be applied for the Reporting Fiscal Year?