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July 30, 2026
Article 8 governs administrative compliance and temporary relief. It mandates the filing of a Top-up Tax Return with the FTA within 15 to 18 months of the fiscal year-end. Significantly, it introduces the Transitional CbCR Safe Harbour, which can reduce Top-up Tax to zero for entities meeting specific revenue, ETR, or profit tests during the transition period. The article also provides for 'Simplified Calculations' for non-material entities and outlines the circumstances under which the FTA may disapply safe harbours, ensuring a balance between administrative ease and robust enforcement of the GloBE rules.
Article 8 - Filing of Top-Up Tax Return and Safe Harbours
Article 8.1 Top-up Tax Return Filing
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