Transitional Safe Harbour Validation Director

The mandate

This project will validate transitional safe-harbour eligibility for a defined jurisdiction population under global minimum-tax rules. The bounded problem is to determine whether the report source, entity perimeter, data adjustments and calculations satisfy each applicable test, and to identify where reliance creates future transition or control risk. It is not a full GloBE implementation.

Milestone one, due in week four, is an accepted population and source-eligibility file covering constituent entities, qualified reporting basis, permanent establishments and required adjustments. Milestone two, due in week ten, is the independently reperformed de minimis, simplified effective-rate and routine-profits calculations with defect and sensitivity records.

The final milestone at week sixteen is a signed eligibility matrix, evidence index, transition-risk register, reviewer training assessment and formal acceptance. Technical acceptance belongs to the Global Minimum Tax Program Lead; data-source and reconciliation acceptance belongs to the nominated financial-reporting owner.

The client supplies country-by-country reports, consolidation records, entity maps, tax data, prior calculations and factual-owner access. Acceptance requires proven source qualification, reconciled perimeter, reproducible tests, approved adjustments and no unresolved critical eligibility defects. Full GloBE calculations, filing preparation, technology selection and structural tax planning are excluded.

What you will own

• Confirm the in-scope constituent-entity and jurisdiction population against ownership, consolidation and tax-residence records.
• Validate whether each reporting source satisfies the applicable qualification requirements and document any permitted adjustments.
• Reperform the de minimis, simplified effective-rate and routine-profits tests from controlled inputs without relying on inherited conclusions.
• Reconcile safe-harbour figures to country reporting, financial records and tax data with clear treatment of basis differences.
• Identify jurisdictions where near-threshold results, data weakness or future fact change makes reliance fragile.
• Create an eligibility decision log recording test selected, evidence, reviewer, conclusion, expiry and transition trigger.
• Train permanent reviewers through a boundary-case exercise and independent reperformance of a selected jurisdiction.
• Submit the accepted matrix, workpapers, source proof, defects, limitations and ownership for future full calculations.

Candidate qualifications

• At least 15 years in international tax, tax accounting or country reporting, including Director-level Pillar Two safe-harbour work.
• A jurisdiction whose apparent safe-harbour result failed after source, perimeter or adjustment testing, with the consequence described.
• Detailed understanding of transitional safe-harbour tests, qualified reports, entity perimeter, simplified covered taxes and routine profits.
• Evidence of reconciling country-report data to financial and tax records without assuming identical definitions.
• Experience assessing threshold sensitivity and explaining why technical eligibility may still require stronger transition preparation.
• Ability to run independent reperformance, record defects and withhold acceptance until critical source issues are cleared.
• Fixed-scope delivery using separate technical and financial-data acceptors.

Working terms and boundaries

• The four-month engagement requires five days a week and is paid through three formal acceptance milestones.
• The program lead accepts technical eligibility; the financial-reporting owner separately accepts source and reconciliation evidence.
• Country reports, consolidation data, entity maps, tax inputs and factual-owner access are client dependencies with agreed dates.
• Full GloBE calculation, filings, platform selection and restructuring are excluded from the project fee.
• Final acceptance requires reproducible tests, resolved critical defects, trained reviewers and explicit ownership of transition risks.

Application

Applications for this mandate are received in one way only: through the India Board Terminal's application process. It is automated end to end. Your Executive Passport travels to the mandate holder in its confidential form, your answers to the three questions below are read before anything else in your file, and every stage that follows is recorded on your applications page.

There is no address to write to and no intermediary to call. The mandate holder reads what the Terminal delivers and nothing else, which is what keeps the process the same for every applicant and keeps your name out of it until you release it. Applications close on 8 October 2026. Mandate reference TAX-CON-2026-MUC-52.