Cayman-Headed Groups

• Is the Cayman entity the ultimate parent under the consolidation and deemed-consolidation rules?
• Does a fund qualify as an excluded entity, and how are controlled operating businesses treated?
• Which intermediate parents and operating jurisdictions apply Pillar Two, and do transparent entities, permanent establishments or joint ventures require separate analysis?

The table distinguishes domestic implementation from OECD qualification. Qualification and safe-harbour eligibility must be checked for the relevant rule and period. Absence from the OECD Central Record does not establish non-enactment or non-qualification. Where implementation is described as not established, this identifies a limitation of the sources reviewed.

• An investment fund or real estate investment vehicle that is the ultimate parent may qualify as an excluded entity. Certain owned entities can also qualify under separate conditions. Do not assume every fund subsidiary or portfolio company is excluded.
• Assess the transitional CbCR safe harbour using qualifying reports and financial data. The OECD extension covers fiscal years beginning on or before 31 December 2027 and ending no later than 30 June 2029. The simplified ETR threshold is 16% for years beginning in 2025 and 17% for years beginning in 2026 or 2027. Confirm domestic application in the jurisdiction applying the rule.
• Subject to eligibility conditions, a jurisdiction can qualify by meeting any one of three transitional CbCR tests: revenue below EUR 10 million and profit before income tax below EUR 1 million; the applicable simplified ETR threshold; or profit before income tax no greater than the substance-based income exclusion. Use the prescribed qualifying data and check the “once out, always out” restriction and its exceptions. These tests differ from the permanent GloBE de minimis exclusion, which generally uses three-year averages.
• Assess the QDMTT Safe Harbour, the Simplified ETR Safe Harbour, the Substance-based Tax Incentive Safe Harbour and relevant entity exclusions separately. Their conditions, elections and effective periods differ. An OECD agreement alone does not establish domestic implementation. Do not assume that Side-by-Side relief applies merely because the group has operations in the United States.
• Relief from top-up tax does not automatically remove registration, notification, return or record-keeping obligations. Retain evidence supporting every relief claimed.

• Ownership chart identifying the ultimate parent, intermediate parents, permanent establishments and ownership percentages.
• Consolidated financial statements and revenue for the four preceding fiscal years.
• Country-by-country reports and the financial records supporting them.
• Jurisdictional accounts, current and deferred taxes, tax incentives, credits and losses.
• Eligible payroll costs and tangible asset carrying values by jurisdiction.
• A compliance register showing responsible entities, elections, registrations and filing deadlines.
• Fund documents and accounting analyses supporting control and consolidation conclusions.
• Details of investment entities, portfolio companies and any claimed excluded-entity treatment.

• GloBE Model Rules — December 2021OECD
• Consolidated Commentary to the GloBE Model Rules — 2026OECD
• Side-by-Side Package — January 2026OECD
• Central Record for the Global Minimum TaxOECD

These links lead to official legislation, guidance or subject-specific resources. The official texts govern.