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Pillar Two: GloBE Return and CbyC Safe Harbours
Cross-border Tax Talks
Is There a Safe Harbor for Taxpayers?
The de minimis test will look at your revenue and pre-tax profit on the C by C data. The effective rate test is an end test, so you need to meet both. And so if you have a qualifying CBCR, that would be a simplifying safe harbor to fall into.
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