India-Headed Groups

• Which overseas subsidiaries benefit from incentives or have low GloBE ETRs?
• Do overseas intermediate parents apply an IIR, and could Indian profits be relevant to a foreign UTPR?
• How should Indian tax credits, losses and deferred taxes be reflected in the applicable calculation?

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.

• Do not infer safe-harbour eligibility from an Indian statutory tax rate above 15%. Test the relevant accounting data, qualifying taxes and conditions in the jurisdiction applying the rule.
• 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.
• Reconciliations of Indian accounting data and tax attributes to GloBE inputs.
• Details of overseas holding companies, incentives and local filing responsibilities.

• 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
• Memorandum Explaining the Provisions in the Finance Bill, 2026Government of India, Ministry of Finance

The Finance Bill memorandum is a budget verification resource. It does not by itself establish whether India has enacted Pillar Two rules through other or subsequent legislation. The domestic implementation status in this guide remains unestablished from the sources reviewed.

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