Pillar Two Safe Harbors: The CbCR journey
Cross-border Tax Talks
Cross-border Tax Talks
Pillar Two Safe Harbors: The CbCR journey
Nov 15, 2023
PwC

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by David Ernick, a Principal with PwC’s Washington National Tax Services Transfer Pricing Practice and former Associate International Tax Counsel at the US Treasury Department, at PwC’s Global Transfer Pricing Conference in San Diego, California. They discuss Country-by-country reporting (CbCR) transitional safe harbor rules, including the safe harbor tests, exclusions to the rules, the difference between the safe harbor rules and the full GLoBE rules, as well as whether a CbCR is ‘qualifying’.  Doug and David also discuss the history and implementation of public CBCR.