MTT15940 - Scope: Safe harbours: Transitional safe harbour: The threshold test

The threshold test is met for a territory for an accounting period when both:

  • the revenue of the members is less than €10 million, and
  • the aggregate profit before income tax of the members is less than €1 million, or a loss.

See MTT15930 and MTT15935 for guidance on determining the profit before income tax and revenue for the purpose of the transitional safe harbour.

This is set out in Paragraph 7, Schedule 16 to Finance (No.2) Act 2023.

Members held for sale

If the group:

  • has members held for sale in the territory, and
  • the revenue of these members is not included in the revenue figure taken from the CbC Report,

an adjustment is required to include the revenue of those members for the purposes of the revenue test.

This adjustment is required because members held for sale may not be included in CbCR but should be considered for MTT purposes.