The long-awaited Side-by-Side (“SbS”) package has finally arrived! Under the SbS system, US-parented groups will have both the SbS and Ultimate Parent Entity (“UPE”) safe harbours applied. What does this mean for Domestic Top-up Tax?
In addition, Transitional Country-by-Country Reporting Safe Harbour (“TCSH”) has been extended for another year. Subsequently, the Simplified Effective Tax Rate (“ETR”) Safe Harbour, which is a permanent safe harbour, will become available. How does this Simplified ETR Safe Harbour compare against the Simplified ETR Test under TCSH?
The Organisation for Economic Co-operation and Development’s January 2026 Administrative Guidance also includes the release of a Substance-based Tax Incentives Safe Harbour, where expenditure-based and certain production-based tax incentives would provide a more favourable ETR outcome for recipients. Is this the same as a Qualified Refundable Tax Credit (“QRTC”)?
Join KPMG in this upcoming webinar to dive into these critical developments and their implications for businesses in the changing global tax landscape.