# Country-by-Country Report Workpaper: [MNE group name] FY[YYYY]

> Preparation workpaper for a country-by-country (CbC) report under OECD/G20
> BEPS Action 13: scope and threshold test, filing and notification plan,
> data sources, the three OECD tables (jurisdiction data, constituent
> entities and activities, additional information), reconciliation to the
> consolidated accounts, data quality checks, the Pillar Two Transitional
> CbCR Safe Harbour check, and the differences for EU public CbCR under
> Directive (EU) 2021/2101. Structure follows the OECD Transfer Pricing
> Guidelines 2022, Chapter V, Annex III, and the OECD Pillar Two
> side-by-side package (January 2026). Replace every `[bracketed]` value and
> every row marked *Example*. This is a document format, not tax, legal,
> accounting or financial advice. Requirements are referenced by number:
> obtain the guidelines or the law for the normative text.

<!--
Guidance: How to use this template
- The CbC report gives tax authorities a jurisdiction-by-jurisdiction view
  of revenue, profit, tax, employees and assets for groups with
  consolidated revenue of EUR 750m or more in the preceding year. The report
  itself is an XML filing; this workpaper documents how each number was
  produced, reviewed and filed.
- Fill section 1 first. If the group is below the threshold, stop at the
  conclusion, or run the workpaper as a dry run to build the data process.
- The CbC data must agree with the Transfer Pricing Master File
  (`finance/transfer-pricing-master-file`) and the local files
  (`finance/transfer-pricing-local-file`). Tax authorities use CbC data for
  risk assessment, so inconsistencies trigger questions.
- Pillar Two: the same data feed the Transitional CbCR Safe Harbour in
  section 9. The full GloBE work is in Pillar Two GloBE Readiness
  (`finance/pillar-two-globe-readiness`); tax figures come from Income Tax
  Provision (`finance/income-tax-provision`).
- Worked example: the fictional Ostrander Group N.V. (retail technology
  group, IFRS reporter, presentation currency EUR, financial year = calendar
  year, parent in the Netherlands, subsidiaries in Germany, the UK, the US
  and Vietnam). Consolidated revenue was EUR 760m in FY2024, EUR 820m in
  FY2025 and EUR 900m in FY2026, so the group files a CbC report for FY2026
  and is in scope of EU public CbCR. Amounts are EUR thousand.
-->

## Document control

<!-- Guidance: One workpaper per reporting fiscal year. Keep the version that matches the filed XML message, with its message reference ID, and never overwrite it after filing; corrections are new versions linked to a corrected XML message. -->

| Field | Value |
|---|---|
| Document ID | [CBCR-FY2026] |
| Version | [1.0] |
| Status | [Draft / In review / Approved / Filed / Superseded] |
| MNE group | [Group name] *Example:* Ostrander Group |
| Reporting entity and role | [Legal name, jurisdiction; ultimate parent / surrogate parent / local filing] *Example:* Ostrander Group N.V., Netherlands, ultimate parent |
| Reporting fiscal year | [YYYY-MM-DD to YYYY-MM-DD] *Example:* 2026-01-01 to 2026-12-31 |
| Reporting currency and units | [EUR thousand] |
| Data source basis | [Consolidation reporting packages / statutory accounts / management accounts] |
| Owner | [@head-of-tax] |
| Prepared by | [@tax-reporting-manager] |
| Approvers/reviewers | [@cfo], [@group-controller], [@tp-manager] |
| Last updated | YYYY-MM-DD |
| Classification | [Confidential: tax data] |
| Filing reference | [XML MessageRefId and submission receipt] |

### Approvals

| Role | Name | Decision | Date |
|---|---|---|---|
| Head of Tax | [@name] | [Approve / Return] | YYYY-MM-DD |
| Group Controller (data and reconciliation) | [@name] | [Confirm / Return] | YYYY-MM-DD |
| Chief Financial Officer | [@name] | [Approve filing] | YYYY-MM-DD |

### Revision history

| Version | Date | Author | Change |
|---|---|---|---|
| 0.1 | YYYY-MM-DD | [@author] | Data request issued and scope test |
| 0.9 | YYYY-MM-DD | [@author] | Tables complete, reconciliation reviewed |
| 1.0 | YYYY-MM-DD | [@author] | Approved for filing |

## Contents

- [1. Scope and threshold test](#1-scope-and-threshold-test)
- [2. Reporting entity, filing and notification plan](#2-reporting-entity-filing-and-notification-plan)
- [3. Data sources and consolidation basis](#3-data-sources-and-consolidation-basis)
- [4. Table 1: data by tax jurisdiction](#4-table-1-data-by-tax-jurisdiction)
- [5. Table 2: constituent entities and activities](#5-table-2-constituent-entities-and-activities)
- [6. Table 3: additional information](#6-table-3-additional-information)
- [7. Reconciliation to the consolidated financial statements](#7-reconciliation-to-the-consolidated-financial-statements)
- [8. Data quality checks and risk indicators](#8-data-quality-checks-and-risk-indicators)
- [9. Transitional CbCR Safe Harbour check](#9-transitional-cbcr-safe-harbour-check)
- [10. EU public country-by-country reporting](#10-eu-public-country-by-country-reporting)
- [11. Review, submission and retention log](#11-review-submission-and-retention-log)
- [12. Glossary and references](#12-glossary-and-references)
- [Standard and licence note](#standard-and-licence-note)

## 1. Scope and threshold test

<!-- Guidance: Decide whether the group must file. Answer: what was consolidated group revenue in the fiscal year before the reporting year, measured in the currency and on the basis the local law uses, and does any local rule set a different threshold? Common pitfall: testing the reporting year itself instead of the preceding year, or ignoring that the US uses a USD threshold. -->

### 1.1 Threshold test

Under the BEPS Action 13 minimum standard, an MNE group files a CbC report
for a fiscal year when its consolidated group revenue in the immediately
preceding fiscal year was at least EUR 750m (or a near equivalent in local
currency as of January 2015). Several jurisdictions express the threshold
in their own currency: the United States uses USD 850m for US-parented
groups filing Form 8975 (Treas. Reg. 1.6038-4), and Vietnam now uses the
equivalent of EUR 750m under Decree 255/2026/ND-CP. Check local law for
the threshold, the currency and the exchange rate to apply.

| Test | Value | Result |
|---|---|---|
| Consolidated revenue, preceding fiscal year FY2025 *(Example)* | EUR 820,000k | At or above EUR 750m |
| Consolidated revenue, reporting year FY2026 (for information, decides FY2027) *(Example)* | EUR 900,000k | At or above EUR 750m |
| Local thresholds that differ *(Example)* | US threshold not relevant (group not US-parented); Vietnam EUR 750m equivalent met | Not applicable |
| Conclusion *(Example)* | | CbC report required for FY2026, filed by the UPE in the Netherlands |

### 1.2 Scope of constituent entities

List every constituent entity: each separate business unit included in the
consolidated financial statements (or that would be if its equity were
traded), entities excluded only on size or materiality grounds, and every
permanent establishment. *Example:* OST-NL, OST-DE, OST-UK, OST-US and
OST-VN as in the master file; no permanent establishments; no entities
excluded on materiality.

## 2. Reporting entity, filing and notification plan

<!-- Guidance: Plan who files where and which notifications each local entity must make. Answer: does the ultimate parent jurisdiction require and exchange the report, are surrogate or local filings triggered, and which notifications fall due when? Common pitfall: missing a local notification deadline, which in many countries carries a penalty even when the report itself is filed correctly by the parent. -->

### 2.1 Reporting entity

| Item | Value |
|---|---|
| Ultimate parent entity (UPE) | [Name, jurisdiction] *Example:* Ostrander Group N.V., Netherlands |
| Does the UPE jurisdiction require CbC filing? | [Yes / No] *Example:* Yes (Corporate Income Tax Act 1969 (Wet Vpb), articles 29b to 29h, implementing DAC4 (check)) |
| Exchange relationships with each jurisdiction of operation | [Qualifying competent authority agreement in effect: Yes / No per jurisdiction] |
| Surrogate parent entity, if any | [Name, jurisdiction, reason] *Example:* None |
| Local filing triggered anywhere? | [Yes / No, jurisdiction, reason] *Example:* No |

### 2.2 Filing and notification calendar (as of 2026-10)

Check local law: notification rules vary more than filing rules.

| Jurisdiction | Legal basis (as of 2026-10) | Obligation | Deadline | Owner |
|---|---|---|---|---|
| Netherlands | Corporate Income Tax Act 1969 (Wet Vpb), articles 29b to 29h, implementing DAC4 (check) | UPE files the CbC report with the Dutch tax administration; Dutch entities notify which entity reports (check) | Report within 12 months of fiscal year end | [@head-of-tax] |
| Germany | Section 138a AO (check the current text) | German entity of a foreign-parented group states in its tax return that it belongs to a group and names the reporting entity | With the tax return (check) | [@de-finance-lead] |
| United Kingdom | UK country-by-country reporting regulations (SI 2016/237) | UK entities notify HMRC which entity files, unless exempt | Notification by the end of the reporting period (check) | [@uk-finance-lead] |
| Vietnam | Decree 255/2026/ND-CP | Vietnamese entity notifies the tax authority on Form 01/TB-BCLN, generally once by the end of the UPE's fiscal year, and updates within 90 days of a change | As stated; confirm in the decree text | [@vn-finance-manager] |
| United States | Treas. Reg. 1.6038-4; Form 8975 | US-parented groups with USD 850m or more file with the UPE's income tax return; foreign-parented groups generally do not file in the US if the parent jurisdiction exchanges | With the return, including extensions | [@us-finance-lead] |
| European Union | Council Directive (EU) 2016/881 (DAC4) | Member states require filing and exchange in line with Action 13, including secondary filing rules | 12 months after fiscal year end | [@head-of-tax] |
| [Other] | [Law] | [Obligation] | [Deadline] | [@owner] |

Secondary (local) filing is the main risk in a foreign-parented group. A
local entity may have to file the full report itself when the parent
jurisdiction does not require one, has no exchange agreement in effect with
the local country, or has systemically failed to exchange. Review the
exchange status each year, because agreements are signed and suspended
over time, and record the conclusion per jurisdiction in 2.1 before the
notification deadlines pass.

## 3. Data sources and consolidation basis

<!-- Guidance: Choose the data source and keep it from year to year. Answer: are the numbers taken from consolidation reporting packages, statutory accounts or management accounts, how are currencies translated, and how are intra-group items treated? Common pitfall: switching data sources between years without explanation, which breaks comparisons that tax authorities run. -->

### 3.1 Source and conventions

| Item | Choice | Reason |
|---|---|---|
| Data source *(Example)* | Consolidation reporting packages (IFRS) before eliminations | Same data as the audited group accounts; available for all entities on the group close timetable |
| Currency translation *(Example)* | Average rate for the year for income items; closing rate for balances (stated capital, accumulated earnings, tangible assets) | Consistent with the group accounts |
| Aggregation *(Example)* | By tax jurisdiction of residence; entities with no tax residence reported as stateless | OECD Annex III instructions |
| Employees *(Example)* | Full-time equivalents at year end | Consistent with the master file; independent contractors counted only if they take part in ordinary operating activities (check guidance) |
| Intra-group dividends *(Example)* | Excluded from revenues and profit before tax in line with OECD implementation guidance | Avoids double counting |

### 3.2 Data request

| Request ID | Data item | Source | Entity owner | Due |
|---|---|---|---|---|
| DR-001 *(Example)* | Revenue split: unrelated and related parties | Reporting package, intercompany module | Entity controllers | Year end plus 6 weeks |
| DR-002 *(Example)* | Profit before tax | Reporting package | Entity controllers | Year end plus 6 weeks |
| DR-003 *(Example)* | Current tax accrued and tax paid in cash | Tax provision and payment records | Tax team | Year end plus 8 weeks |
| DR-004 *(Example)* | Stated capital and accumulated earnings | Statutory balance sheet | Entity controllers | Year end plus 8 weeks |
| DR-005 *(Example)* | FTE at year end | HR system | HR | Year end plus 4 weeks |
| DR-006 *(Example)* | Tangible assets other than cash | Fixed asset register | Entity controllers | Year end plus 6 weeks |

The fixed asset data usually come from Fixed Asset Register
(`finance/fixed-asset-register`); intercompany revenue comes from the
intercompany matching process covered by Account Reconciliation
(`finance/account-reconciliation`).

## 4. Table 1: data by tax jurisdiction

<!-- Guidance: Table 1 is the core of the report. Answer, per jurisdiction: revenues from unrelated and related parties, profit or loss before income tax, income tax paid (cash), income tax accrued (current year), stated capital, accumulated earnings, number of employees and tangible assets other than cash. Common pitfall: reporting deferred tax or uncertain tax provisions in "income tax accrued"; it should be current-year current tax expense only. -->

### 4.1 Column definitions (summary)

| Column | Summary of what to include |
|---|---|
| Revenues, unrelated party | Revenue from independent parties, including sales, services, royalties, interest and other income; exclude intra-group dividends |
| Revenues, related party | Revenue from other constituent entities of the group |
| Profit or loss before income tax | Sum for all constituent entities in the jurisdiction, including extraordinary items |
| Income tax paid (cash basis) | Cash taxes paid in the year to any jurisdiction, including withholding tax suffered |
| Income tax accrued (current year) | Current tax expense on the year's taxable profits; exclude deferred tax and provisions for uncertain positions |
| Stated capital | Stated capital of the constituent entities; for permanent establishments, as reported by the head office |
| Accumulated earnings | Total accumulated earnings at year end |
| Number of employees | FTE or headcount at year end, on a consistent basis |
| Tangible assets other than cash | Net book value; exclude cash, cash equivalents, intangibles and financial assets |

### 4.2 Table 1 data

| Jurisdiction | Revenues unrelated | Revenues related | Revenues total | Profit before tax | Tax paid | Tax accrued | Stated capital | Accumulated earnings | Employees | Tangible assets |
|---|---|---|---|---|---|---|---|---|---|---|
| NL *(Example)* | 300,000 | 518,120 | 818,120 | 66,180 | 17,100 | 18,545 | 120,000 | 310,000 | 1,400 | 52,000 |
| DE *(Example)* | 210,000 | 0 | 210,000 | 6,300 | 1,750 | 1,890 | 10,000 | 18,000 | 600 | 9,000 |
| GB *(Example)* | 150,000 | 0 | 150,000 | 4,500 | 1,020 | 1,125 | 8,000 | 14,000 | 450 | 6,500 |
| US *(Example)* | 225,000 | 0 | 225,000 | 3,630 | 840 | 901 | 15,000 | 9,500 | 650 | 9,500 |
| VN *(Example)* | 15,000 | 116,640 | 131,640 | 9,390 | 850 | 939 | 20,000 | 21,000 | 2,900 | 18,000 |
| **Total** | **900,000** | **634,760** | **1,534,760** | **90,000** | **21,560** | **23,400** | **173,000** | **372,500** | **6,000** | **95,000** |

Check: related revenues 518,120 + 116,640 = 634,760; total revenues 818,120 + 210,000 + 150,000 + 225,000 + 131,640 = 1,534,760; profit before tax 66,180 + 6,300 + 4,500 + 3,630 + 9,390 = 90,000; tax accrued 18,545 + 1,890 + 1,125 + 901 + 939 = 23,400; tax paid 17,100 + 1,750 + 1,020 + 840 + 850 = 21,560.

Tax accrued is the current tax on FY2026 taxable profits per jurisdiction, as computed in Income Tax Provision (`finance/income-tax-provision`, section 3.2: current tax before adjustments less credits). It excludes the FY2025 Netherlands return-to-provision credit (250) and the German uncertain tax position charge (250), which net to zero in the consolidated current tax expense of 23,400 (see section 7). Vietnam's accrued tax is 10% of profit before tax because OST-VN applies a preferential corporate income tax rate of 10% for qualifying software production (*Example*; check the current Vietnamese incentive law and the entity's eligibility).

The US profit before tax (3,630) is after interest of 3,120 on loan FIN-001: operating profit 6,750 (3.0% of 225,000) less 3,120.

### 4.3 Build-up of related-party revenues

| Jurisdiction | Component | Amount (EUR thousand) | Source |
|---|---|---|---|
| NL *(Example)* | Sales of subscriptions and goods to OST-DE | 175,000 | Intercompany ledger |
| NL *(Example)* | Sales of subscriptions and goods to OST-UK | 125,000 | Intercompany ledger |
| NL *(Example)* | Sales of subscriptions and goods to OST-US | 190,000 | Intercompany ledger |
| NL *(Example)* | Sales of goods to OST-VN | 12,000 | Intercompany ledger |
| NL *(Example)* | Group service charges to OST-DE, OST-UK, OST-US, OST-VN (4,000 + 3,000 + 4,500 + 1,500) | 13,000 | Allocation file |
| NL *(Example)* | Interest on loan FIN-001 to OST-US | 3,120 | Treasury system |
| VN *(Example)* | Development service fee from OST-NL (CT-001) | 116,640 | Local file 3.1 |
| **Total** | | **634,760** | |

Check: 175,000 + 125,000 + 190,000 + 12,000 + 13,000 + 3,120 = 518,120 for NL; 518,120 + 116,640 = 634,760.

## 5. Table 2: constituent entities and activities

<!-- Guidance: List every constituent entity by jurisdiction with its main business activities, using the OECD activity categories. Answer: what does each entity actually do? Common pitfall: ticking every box for every entity, which makes the table useless and inconsistent with the master file functional analysis. -->

The OECD template offers a fixed list of activity categories, including
research and development, holding or managing intellectual property,
purchasing or procurement, manufacturing or production, sales, marketing
or distribution, administrative, management or support services, services
to unrelated parties, internal group finance, regulated financial
services, insurance, holding shares or other equity instruments, dormant,
and other (with an explanation in Table 3).

| Jurisdiction | Entity ID and name | Tax residence if different | Main activities *(Example)* |
|---|---|---|---|
| NL | OST-NL Ostrander Group N.V. | | Research and development; holding or managing IP; purchasing or procurement; sales, marketing or distribution; administrative, management or support services; internal group finance; holding shares or other equity instruments |
| DE | OST-DE Ostrander Deutschland GmbH | | Sales, marketing or distribution; services to unrelated parties |
| GB | OST-UK Ostrander UK Ltd | | Sales, marketing or distribution; services to unrelated parties |
| US | OST-US Ostrander Inc | | Sales, marketing or distribution; services to unrelated parties |
| VN | OST-VN Ostrander Vietnam Co., Ltd | | Research and development; sales, marketing or distribution |

Check each line against the master file functional table (section 3.5 of
`finance/transfer-pricing-master-file`). *Example:* OST-VN performs
research and development as a contract service provider; ticking "holding
or managing IP" for it would contradict the master file.

## 6. Table 3: additional information

<!-- Guidance: Use Table 3 to explain data sources, conventions and anything a reader could misread. Keep it short and factual. Common pitfall: leaving it empty, so a tax authority assumes the worst about unusual numbers such as high profit per employee. -->

Draft text for Table 3 *(Example)*:

- Data source: IFRS consolidation reporting packages before intra-group
  eliminations; same source as in prior years.
- Currency: EUR; income items translated at average rates for FY2026
  (GBP 0.86, USD 1.10, VND 28,500 per EUR), balances at closing rates.
- Employees: full-time equivalents at 2026-12-31.
- Tangible assets: net book value including right-of-use assets under
  IFRS 16; excluding cash, intangibles and financial assets.
- Netherlands: profit reflects the parent's role as owner of the platform and
  brand and the bearer of development and market risks, as documented in
  the master file.
- Netherlands: tax accrued of 28.0% of profit before tax is above the
  25.8% headline rate because share-based payments, costs of an aborted
  share acquisition and other items are not deductible.
- Vietnam: revenues are mainly a cost-plus development fee from the parent;
  low revenue per employee reflects a labour-intensive service activity.
  Tax accrued reflects a 10% preferential corporate income tax rate for
  qualifying software production.
- Intra-group dividends: none received in FY2026.

## 7. Reconciliation to the consolidated financial statements

<!-- Guidance: CbC data are not required to reconcile to the consolidated accounts, but an internal reconciliation is the best control against errors. Answer: do aggregated revenues less eliminations equal consolidated revenue, and is any difference in profit explained? Common pitfall: reporting consolidated figures (after eliminations) for a jurisdiction instead of the aggregate of its entities. -->

| Line | CbC Table 1 (EUR thousand) | Eliminations and adjustments | Consolidated accounts | Difference |
|---|---|---|---|---|
| Revenues *(Example)* | 1,534,760 | (634,760) intra-group revenues | 900,000 | 0 |
| Profit before tax *(Example)* | 90,000 | 0 (unrealised intra-group profit in closing inventory immaterial) | 90,000 | 0 |
| Current tax expense *(Example)* | 23,400 | 0 net: German uncertain tax position charge 250, Netherlands FY2025 return-to-provision credit (250) | 23,400 | 0 |
| Employees (FTE) *(Example)* | 6,000 | 0 | 6,000 | 0 |

Check: 1,534,760 - 634,760 = 900,000.

Explain every non-zero difference, for example unrealised profit on
intra-group inventory, purchase price allocation amounts booked only at
group level, or entities consolidated using a different year end. Keep the
reconciliation file as evidence; it is not part of the filed report.

## 8. Data quality checks and risk indicators

<!-- Guidance: Look at the data as a tax authority will. Answer: which ratios look unusual, and is the explanation documented in Table 3, the master file or the local files? Common pitfall: discovering an unexplained outlier only when a tax inspector asks about it. -->

### 8.1 Validation checks

| Check ID | Check | Result *(Example)* |
|---|---|---|
| QC-001 | Every entity in Table 2 belongs to a jurisdiction in Table 1 | Pass |
| QC-002 | Related revenues equal the intercompany ledger after matching | Pass (difference EUR 0k) |
| QC-003 | Tax accrued excludes deferred tax and uncertain tax provisions | Pass |
| QC-004 | Employees agree with HR data and the master file | Pass (6,000) |
| QC-005 | Tangible assets exclude cash, intangibles and financial assets; state in Table 3 whether right-of-use assets are included | Pass (right-of-use assets included, stated in Table 3) |
| QC-006 | XML passes schema validation in the filing portal | [Pass / Fail, error code] |
| QC-007 | Signs: losses shown as negative numbers | Pass (no losses) |

### 8.2 Risk indicators by jurisdiction

| Jurisdiction | Profit before tax per employee | Revenue per employee | Tax accrued / profit before tax | Related revenues / total revenues | Tax paid / tax accrued |
|---|---|---|---|---|---|
| NL *(Example)* | 47.27 | 584.4 | 28.0% | 63.3% | 92.2% |
| DE *(Example)* | 10.50 | 350.0 | 30.0% | 0.0% | 92.6% |
| GB *(Example)* | 10.00 | 333.3 | 25.0% | 0.0% | 90.7% |
| US *(Example)* | 5.58 | 346.2 | 24.8% | 0.0% | 93.2% |
| VN *(Example)* | 3.24 | 45.4 | 10.0% | 88.6% | 90.5% |
| Group *(Example)* | 15.00 | 150.0 (external revenues) | 26.0% | 41.4% | 92.1% |

Check (NL): 66,180 / 1,400 = 47.27; 818,120 / 1,400 = 584.4; 18,545 / 66,180 = 28.0%; 518,120 / 818,120 = 63.3%; 17,100 / 18,545 = 92.2%. VN: 939 / 9,390 = 10.0%; 850 / 939 = 90.5%. Group: 90,000 / 6,000 = 15.00; 900,000 / 6,000 = 150.0; 23,400 / 90,000 = 26.0%; 634,760 / 1,534,760 = 41.4%; 21,560 / 23,400 = 92.1%.

*Example:* The Netherlands shows four to five times the profit per
employee of the distributors because it bears the entrepreneurial risks
and owns the platform. This
is consistent with the master file and is explained in Table 3. Vietnam's
10.0% tax ratio is the most visible outlier: a reviewer will ask about it,
so Table 3 names the preferential rate, and the Pillar Two position is
documented in section 9. Tax paid
is below tax accrued in every country because final payments for FY2026
fall due in 2027; no further explanation needed.

## 9. Transitional CbCR Safe Harbour check

<!-- Guidance: For groups in scope of Pillar Two, test each jurisdiction against the three tests of the Transitional CbCR Safe Harbour using qualified CbC data and financial statement data. Answer: does the jurisdiction pass the de minimis, simplified ETR or routine profits test for the year? Common pitfall: using CbC data that are not "qualified" (for example management accounts), which removes access to the safe harbour. -->

### 9.1 Rules in brief (as of 2026-10)

- The safe harbour was agreed by the OECD/G20 Inclusive Framework in
  December 2022 for a transition period. The side-by-side package
  (approved in January 2026) extended it by one year: it now covers fiscal
  years beginning on or before 31 December 2027, excluding fiscal years
  ending after 30 June 2029.
- Transition rate for the simplified ETR test: 15% for fiscal years
  beginning in 2023 and 2024, 16% for 2025, and 17% for 2026 and 2027.
- De minimis test: total revenues below EUR 10m and profit before tax below
  EUR 1m in the jurisdiction.
- Routine profits test: profit before tax not above the substance-based
  income exclusion (payroll and tangible asset carve-outs at the transition
  rates of the GloBE Model Rules, Article 9.2) for the jurisdiction.
- A permanent Simplified ETR Safe Harbour replaces the simplified ETR test
  from 2027 (from 2026 in certain circumstances); groups can choose between
  the two during the overlap.
- Domestic implementation decides availability: check each jurisdiction's
  law (for example the EU Pillar Two Directive (EU) 2022/2523 as transposed,
  and local qualified domestic minimum top-up taxes).

### 9.2 Simplified ETR test, FY2026 (illustrative)

Simplified ETR = income tax expense in the qualified financial statements
(current plus deferred, excluding taxes that are not covered taxes and
uncertain tax positions) divided by profit before tax in the qualified CbC
report.

| Jurisdiction | Current tax accrued | Prior-year adjustment in the accounts | Deferred tax expense (credit) | Simplified covered taxes | Profit before tax | Simplified ETR | Transition rate | Result |
|---|---|---|---|---|---|---|---|---|
| NL *(Example)* | 18,545 | (250) | 516 | 18,811 | 66,180 | 28.42% | 17% | Pass |
| DE *(Example)* | 1,890 | 0 | 60 | 1,950 | 6,300 | 30.95% | 17% | Pass |
| GB *(Example)* | 1,125 | 0 | 40 | 1,165 | 4,500 | 25.89% | 17% | Pass |
| US *(Example)* | 901 | 0 | (16) | 885 | 3,630 | 24.38% | 17% | Pass |
| VN *(Example)* | 939 | 0 | 0 | 939 | 9,390 | 10.00% | 17% | Fail: test routine profits |

Check: deferred 516 + 60 + 40 - 16 + 0 = 600, equal to the group deferred
tax expense in the master file and in the income tax provision;
18,545 - 250 + 516 = 18,811 and 18,811 / 66,180 = 28.42%; 939 / 9,390 =
10.00%. The German uncertain tax position charge (250) is excluded from
simplified covered taxes, as the safe harbour requires; the Netherlands
FY2025 true-up stays in because it is part of the income tax expense in
the qualified financial statements (check the current guidance on
prior-year items).

### 9.3 Routine profits test for Vietnam, FY2026

| Item | Amount (EUR thousand) |
|---|---|
| Eligible payroll costs *(Example)* | 86,400 |
| Payroll carve-out at 9.4% *(Example)* | 8,122 |
| Eligible tangible assets, average of opening and closing carrying value (opening and closing both about 18,000) *(Example)* | 18,000 |
| Tangible asset carve-out at 7.4% *(Example)* | 1,332 |
| Substance-based income exclusion (SBIE) *(Example)* | 9,454 |
| Profit before tax in the qualified CbC report *(Example)* | 9,390 |
| Margin (SBIE less profit before tax) *(Example)* | 64 |
| Result *(Example)* | Pass: profit before tax does not exceed the SBIE |

Check: 86,400 x 9.4% = 8,121.6; 18,000 x 7.4% = 1,332.0; 8,121.6 +
1,332.0 = 9,453.6, rounded to 9,454; 9,454 - 9,390 = 64.

The group is in scope of Pillar Two for FY2026 because consolidated revenue
was at least EUR 750m in at least two of the four preceding years (FY2023
EUR 755m, FY2024 EUR 760m and FY2025 EUR 820m all qualify); confirm with Pillar Two GloBE Readiness
(`finance/pillar-two-globe-readiness`).

*Example:* Vietnam fails the simplified ETR test at 10.00% because of the
10% preferential rate, and fails the de minimis test (revenues of 131,640
are above EUR 10m), but passes the routine profits test by a margin of
only EUR 64k, as it did in FY2025 (see Pillar Two GloBE Readiness, section
3.1). The top-up tax for Vietnam is therefore deemed zero under the
Transitional CbCR Safe Harbour for FY2026, and the Vietnamese domestic
minimum top-up tax should also be zero (check that Decree 236/2025/ND-CP
applies the safe harbour to the domestic top-up tax). The margin is
thin: a higher development fee, lower payroll or the lower FY2027
carve-out rates (9.2% and 7.2%) could turn the pass into a fail, so keep
the full GloBE computation as a shadow calculation every year. A
jurisdiction that fails all tests in one year cannot use the safe harbour
in later years.

## 10. EU public country-by-country reporting

<!-- Guidance: EU public CbCR is a separate, public disclosure under the Accounting Directive, with a narrower data set and a different jurisdiction breakdown. Answer: is the group in scope, which entity publishes, which jurisdictions must be shown separately, and is any information deferred under the safeguard clause? Common pitfall: publishing the confidential OECD report as-is, which discloses more than the law requires and may breach confidentiality expectations. -->

### 10.1 Scope

Directive (EU) 2021/2101 amended Directive 2013/34/EU (Articles 48a to
48j) to require public income tax information reports from groups and
standalone undertakings whose consolidated revenue exceeded EUR 750m on
the balance sheet date for each of the last two consecutive financial years, including non-EU groups with
qualifying EU subsidiaries or branches. Member states apply it from the
first financial year starting on or after 22 June 2024; for calendar-year
groups the first report covers FY2025 and is due by the end of 2026. Check
national transposition and the consolidated text.

| Test *(Example)* | Value | Result |
|---|---|---|
| Consolidated revenue above EUR 750m in FY2025 and FY2026 (the two years ending with the reporting year)? | EUR 820,000k and EUR 900,000k | Yes |
| Was FY2025 also reportable (FY2024 and FY2025 both above the threshold)? | EUR 760,000k and EUR 820,000k | Yes: first report for FY2025 due by 2026-12-31 |
| Conclusion | | In scope; OST-NL publishes the FY2026 report by 2027-12-31 |

Confirm whether the threshold test refers to the reporting year and the
preceding year, or to the two years before the reporting year, in the
national transposition; the example assumes the reporting year and the
preceding year.

### 10.2 Example public report, FY2026

Revenues here follow the OECD Table 1 definition (unrelated plus related),
which the Directive allows as an alternative presentation (check the
consolidated text and the national law). Only EU member states are shown
separately; no group entity is in a jurisdiction on Annex I or Annex II of
the EU list at the reporting date (check the list in force), so all other
jurisdictions are aggregated.

| Jurisdiction | Activities | Employees (FTE) | Revenues | Profit before tax | Income tax accrued | Income tax paid | Accumulated earnings |
|---|---|---|---|---|---|---|---|
| Netherlands *(Example)* | Group management, platform ownership, sales | 1,400 | 818,120 | 66,180 | 18,545 | 17,100 | 310,000 |
| Germany *(Example)* | Distribution | 600 | 210,000 | 6,300 | 1,890 | 1,750 | 18,000 |
| Rest of the world (UK, US, Vietnam) *(Example)* | Distribution, software development | 4,000 | 506,640 | 17,520 | 2,965 | 2,710 | 44,500 |
| **Total** | | **6,000** | **1,534,760** | **90,000** | **23,400** | **21,560** | **372,500** |

Check: rest of the world revenues 150,000 + 225,000 + 131,640 = 506,640; profit before tax 4,500 + 3,630 + 9,390 = 17,520; tax accrued 1,125 + 901 + 939 = 2,965; tax paid 1,020 + 840 + 850 = 2,710; accumulated earnings 14,000 + 9,500 + 21,000 = 44,500; employees 450 + 650 + 2,900 = 4,000.

Add a short narrative explaining material differences between tax accrued
and tax paid, as the Directive expects (check Article 48c). *Example:*
Tax paid is below tax accrued in every jurisdiction because final payments
for FY2026 fall due in 2027.

### 10.3 Differences from the OECD CbC report

| Topic | OECD CbC report (confidential) | EU public report (Article 48c; check the consolidated text) |
|---|---|---|
| Audience | Tax authorities only | Public, on the company website and in the business register |
| Jurisdiction breakdown | Every jurisdiction | Each EU member state separately; each jurisdiction on the EU list of non-cooperative jurisdictions (Annex I) and, under conditions, Annex II separately; all other jurisdictions aggregated as "rest of the world" |
| Data items | Table 1 to 3 | Name of the parent, financial year, currency, list of EU and listed-jurisdiction subsidiaries, description of activities, employees, revenues, profit or loss before tax, income tax accrued, income tax paid, accumulated earnings |
| Items not required | Not applicable | Stated capital and tangible assets are not required |
| Deferral | Not applicable | Commercially sensitive items may be omitted temporarily (up to five years, with disclosure of the omission), never for listed non-cooperative jurisdictions |
| Deadline | 12 months after year end | Published within 12 months of the balance sheet date and kept accessible for at least five years |
| Format | OECD XML schema | Common template and machine-readable electronic formats set by Commission Implementing Regulation (EU) 2024/2952 (check the current act) |
| Assurance | None | Statutory auditor states whether the report was required and published (check national law) |

### 10.4 Publication plan

| Step | Owner | Date |
|---|---|---|
| Map entities to EU, Annex I, Annex II and rest-of-world groups | [@tax-reporting-manager] | YYYY-MM-DD |
| Draft narrative and data from Table 1 | [@tax-reporting-manager] | YYYY-MM-DD |
| Safeguard clause decision and documentation | [@head-of-tax], [@legal] | YYYY-MM-DD |
| Board approval and publication on the website | [@company-secretary] | YYYY-MM-DD |
| Filing in the business register | [@company-secretary] | YYYY-MM-DD |

Consider aligning the narrative with the group's Tax Strategy Statement
(`finance/tax-strategy-statement`), because readers will compare them.

## 11. Review, submission and retention log

<!-- Guidance: Record the review evidence and the filing receipts. Answer: who reviewed which part, when was the XML submitted, and was it accepted? Common pitfall: losing the message reference IDs needed to file a correction. -->

| Step | Owner | Date | Evidence |
|---|---|---|---|
| Data received from all entities | [@tax-reporting-manager] | YYYY-MM-DD | [Data request tracker] |
| Reconciliation reviewed (section 7) | [@group-controller] | YYYY-MM-DD | [Reconciliation file] |
| Consistency with master and local files | [@tp-manager] | YYYY-MM-DD | [Review notes] |
| Approval to file | [@cfo] | YYYY-MM-DD | [Approval record] |
| XML generated and validated | [@tax-reporting-manager] | YYYY-MM-DD | [Validation report] |
| Submitted to [tax authority] | [@head-of-tax] | YYYY-MM-DD | [Receipt, MessageRefId] |
| Status message received | [@head-of-tax] | YYYY-MM-DD | [Accepted / Errors to correct] |
| Local notifications filed | [@local-finance-leads] | YYYY-MM-DD | [Receipts] |

Retain the workpaper, the XML, the receipts and the source data for at
least the longest statutory retention period among the group's
jurisdictions. Record any correction as a new version with the corrected
message reference.

### 11.1 Lessons for next year

*Example:* The FY2026 preparation took three weeks longer than planned
because tangible asset data for Vietnam were held only in local accounting
software. Action ACT-001: map local fixed asset accounts to the group
chart before the FY2027 close. Owner: [@group-controller]. Due: 2027-03-31.

## 12. Glossary and references

<!-- Guidance: Define each acronym once and record the sources and the date checked. -->

### 12.1 Glossary

| Term | Meaning |
|---|---|
| BEPS | Base erosion and profit shifting, the OECD/G20 project that set the CbC minimum standard (Action 13) |
| CbC report | Country-by-country report under BEPS Action 13 |
| Constituent entity | A business unit or permanent establishment of the MNE group included in the report |
| DAC4 | Council Directive (EU) 2016/881 on the automatic exchange of CbC reports |
| GloBE | Global Anti-Base Erosion rules (Pillar Two) |
| Qualified CbC report | A CbC report prepared from qualified financial statements, as needed for the Transitional CbCR Safe Harbour |
| Surrogate parent entity | A group entity appointed to file in place of the ultimate parent |
| Transition rate | The minimum simplified ETR for the safe harbour in a given year |
| UPE | Ultimate parent entity |

### 12.2 References

| Reference | Version or date checked | Use |
|---|---|---|
| OECD Transfer Pricing Guidelines 2022, Chapter V, Annex III | 2022 edition, checked 2026-10-25 | Table structure and column summary |
| OECD/G20 Inclusive Framework, Pillar Two Side-by-Side Package | January 2026 (approved 2026-01-05) | Extension of the Transitional CbCR Safe Harbour; transition rates |
| Directive (EU) 2021/2101 amending Directive 2013/34/EU | Adopted 24 November 2021; applies from financial years starting on or after 22 June 2024 | EU public CbCR |
| Council Directive (EU) 2016/881 (DAC4) | Checked 2026-10-25 | EU filing and exchange |
| US Treas. Reg. 1.6038-4 | eCFR text checked 2026-10-25 | USD 850m threshold and Form 8975 timing |
| Vietnam Decree 255/2026/ND-CP | Effective 2026-07-01 | EUR 750m equivalent threshold; Form 01/TB-BCLN |
| Germany section 138a AO; UK SI 2016/237 | Not re-checked; confirm | Filing and notification rows |

## Standard and licence note

Structure aligned with the OECD Transfer Pricing Guidelines for
Multinational Enterprises and Tax Administrations 2022, Chapter V,
Annex III, and based on the OECD/G20 Inclusive Framework Pillar Two
Side-by-Side Package (January 2026, © OECD 2026, published under CC BY 4.0
as OECD material issued from 2024-07-01; earlier OECD material is used for
structure and references only under the OECD terms and conditions). This
is an adaptation in original wording; it does not represent the official
views of the OECD or its Member countries. EU law (Directive (EU)
2021/2101, Council Directive (EU) 2016/881) is cited by article and
summarised in original words (EUR-Lex reuse with acknowledgement); US
Treas. Reg. 1.6038-4 is US public domain; the Vietnamese, German and UK
rows are paraphrased from public law. Ostrander Group N.V., its subsidiaries and
every figure are fictional. This template is original text written for this
collection. Check the current official versions of the guidelines and each
law before use. Template licence: MIT.