Safe-Harbour Claims: The Evidence You Should Retain

Record the tested jurisdiction, fiscal-year dates, collecting rule and safe-harbour route. Explain the legal and factual conditions relied on and identify who reviewed them. Keep different reliefs separate: a Transitional CbCR test, Simplified ETR route, QDMTT safe harbour and Side-by-Side election may share source documents, but their eligibility conditions and evidence requirements are not interchangeable. Save the applicable guidance and domestic-law confirmation. An older assessment can be useful history, but it does not establish that the conditions, entity population or recognition status remain the same in the next period. Document changes rather than copying the prior conclusion without review.

Retain the relevant accounts, reporting packages, tax schedules and reconciliations. Explain any currency conversions, classification decisions or adjustments. For a fictional team screening a CbCR route, an attractive percentage in a dashboard is not enough if the underlying report and accounting sources have not been established as qualifying. Keep the original data and the transformations that produced the tested figures. Where another team supplies a number, identify its owner and preparation basis. Do not replace missing support with an eligibility confirmation simply because the software allows the calculation to continue.

Record previous claims, entry or re-entry history and any conditions relevant to the particular relief. For parent-regime relief, retain the recognition and period evidence; for an incentive-related claim, keep the incentive terms and supporting classification analysis. Address interactions, exclusions and any reasons a route was not available. Do not keep only successful calculations. An unsuccessful test may explain why a full calculation was required or why later eligibility needs attention. The file should show the decision path, including advice received and unresolved points, without suggesting that every international simplification automatically applies under domestic law.

Save the election or return evidence, reviewer approval and correspondence addressing questions. Apply the relevant local record-retention rules and group controls, including arrangements for acquisitions, staff changes and adviser handovers. If a claim cannot be reconstructed from the existing file, identify the gap before relying on it again. Bring us the worksheet, source records and election history if the evidence is fragmented. We can help organise a review of the missing conditions and coordinate local confirmation. A defensible file supports the relief claimed; it does not claim to guarantee that an authority will agree with every judgement.