Pillar Two: GloBE Return and CbyC Safe Harbours
Cross-border Tax Talks
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What Are the Safe Harbors for C by CR?
Taxpayers will have to look at qualified financial statements again. Stateless constituent entities and multi-parent, multinational enterprises with no single qualifying country by country report are excluded from the safe harbor. They cannot rely on the stateless jurisdiction in country by country or for multi-parented enterprises.
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