Three transitional tests
The June 2026 edition explains the transitional CbCR safe harbour using qualified country-by-country reporting and financial information. A jurisdiction can qualify through the de minimis test, the simplified ETR test or the routine-profits test. The illustrated de minimis thresholds are revenue below EUR10 million and profit before tax below EUR1 million. The simplified ETR thresholds shown are 16% for financial years beginning in 2025 and 17% for 2026. Routine profits compare profit before tax with the substance-based exclusion. These are alternative jurisdictional tests, not a company-by-company exemption.
Elections and subsequent guidance
The presentation describes annual elections, the once-out-always-out restriction, excluded entity categories and the QDMTT safe harbour. Simplified calculations for non-material constituent entities have their own requirements. Preserve the qualified-source evidence and earlier-year elections before claiming relief. The edition’s transitional window must be read alongside later Side-by-Side guidance and Singapore implementation updates; an OECD announcement should not be treated as an automatically enacted Singapore extension.
Official source
A concise, independent Apex Gateway guide based on the official English source, not a reproduction of the complete document. Consult the original for full conditions, exceptions and subsequent updates.
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