Accessing the transitional safe harbour – August 2025

Despite the political headwinds the OECD’s Pillar Two framework continues to face, Pillar Two is enacted legislation in Australia. In-scope groups must therefore continue their preparation to meet Australia’s Global Minimum Tax and Domestic Minimum Tax obligations. Most groups intend to elect into the Transitional Safe Harbour for eligible jurisdictions, which provides welcome compliance relief when compared to performing a full GloBE computation. In this article of Deloitte’s Pillar Two in Australia series, we reflect on relevant aspects such as the ‘Qualified’ Financial Statements and ‘Qualified’ Country-by Country Report that are critical to ensure that sought-after Transitional Safe Harbour access.