‘‘Safe Harbour’’
means an exception provided in Article 8.2.1 of the GloBE Model Rules whose design and eligibility conditions have been approved by the Inclusive Framework and set out in—
| (a) | OECD (2022), Safe Harbours and Penalty Relief: Global Anti-Base Erosion Rules (Pillar Two), OECD/G20 Inclusive Framework on BEPS, OECD, Paris; |
| (b) | Administrative Guidance to the GloBE Model Rules; and |
| (c) | any similar document subsequently released by the Inclusive Framework as specified under section 23; and |