Global Minimum Tax: Ebner Stolz Transitional CBCR Safe Harbour Quick Check as First Assessment of the Need for Action

As of 2024, large cor­po­rate groups have to as­sess for the first time the ex­tent to which a top-up tax is payable due to the re­qui­re­ments of the glo­bal mi­ni­mum tax (Pil­lar II). In this con­text, even if all group en­ti­ties are re­si­dent in ju­ris­dic­tions with a no­mi­nal cor­po­rate tax rate far above the mi­ni­mum tax rate of 15 %, the is­sue of the glo­bal mi­ni­mum tax is not sett­led. Howe­ver, tem­porary sim­pli­fi­ca­ti­ons might be ap­plica­ble. Our tool-ba­sed ap­proach with the RSM Eb­ner Stolz Tran­si­tio­nal CbCR Safe Har­bour Quick Check pro­vi­des an in­itial as­sess­ment.