OECD Pillar Two: expiry of Safe Harbours and the 2026 horizon

The clock is ticking

The Transitional CbCR Safe Harbours of Pillar Two, designed to ease compliance during the early years, expire for fiscal years starting after 31 December 2026. From that point, in-scope groups must compute the GloBE Effective Tax Rate jurisdiction by jurisdiction under the full methodology.

What Safe Harbours cover today

1. De minimis: revenue < EUR 10M and profit < EUR 1M in a jurisdiction.
2. Simplified ETR: adjusted ETR ≥ 15% (2024), 16% (2025), 17% (2026) using CbCR data.
3. Routine profits: pre-tax profit ≤ substance-based income exclusion.

Meeting one is enough to keep the jurisdiction within safe harbour.

Why it matters for LatAm

Many Colombian, Mexican and Brazilian groups with subsidiaries in low-tax jurisdictions (Panama, Bahamas, certain US states, free zones) have relied on these harbours so far. Expiry requires:

• GloBE-ready information systems (local account mapping to Adjusted Covered Taxes).
• Modelling of QDMTT impact in each substance jurisdiction.
• Review of intragroup financing and royalty structures.

Recommended actions over the next 12 months

• GloBE audit of the top five jurisdictions by exposure.
• Pilot the Information Return (GIR) during 2026.
• Evaluate reorganisations that leverage the grace period.