Transitional Safe Harbour for CbCR: Qualification and Tests

JAKARTA – Multinational groups subject to the global minimum tax must ensure their Country‑by‑Country Report (CbCR) meets the qualifications set out in Ministry of Finance Regulation (PMK) No 136/2024. A qualified CbCR enables the use of the transitional safe harbour for fiscal years that start on or before 31 December 2026 and end no later than 30 June 2028.

A qualified CbCR is one prepared on qualified financial statements, i.e., the consolidated financial statements of the ultimate parent entity or separate statements of each constituent entity prepared under an accepted accounting standard. To qualify for the safe harbour, each constituent must satisfy at least one of three tests: the de minimis test (revenue below EUR 10 million and pre‑tax profit below EUR 1 million), the routine profit test (pre‑tax profit not exceeding the Substance‑Based Income Exclusion amount), or the simplified ETR test (simplified effective tax rate of 15 %‑17 % depending on the fiscal year).

When any test is met, additional tax in that jurisdiction is treated as zero, lowering the compliance burden and potential extra tax for the group during the early rollout of the global minimum tax. Regulators expect the mechanism to streamline reporting and reduce administrative costs.