The OECD/G20 Inclusive Framework on BEPS has released new administrative guidance on the application of the Transitional UTPR Safe Harbour to MNE groups with a 53-week fiscal year.
Where an MNE group with a 53-week fiscal year has its UPE located in a jurisdiction eligible for both for the Transitional UTPR Safe Harbour, and for fiscal years starting on or after 1 January 2026, the Side-by-Side (SbS) Safe Harbour or the UPE Safe Harbour, the guidance confirms that the MNE group remains eligible for the Transitional UTPR Safe Harbour until the SbS Safe Harbour or UPE Safe Harbour becomes applicable.
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