{
  "tool_id": "art-456-globe-safe-harbour-tests",
  "kernel_id": "art-456-globe-safe-harbour-tests",
  "display_name": "GloBE Transitional Safe Harbour Test Evaluator",
  "tool_version": "1.0.0",
  "mandate_type": "compliance_control",
  "purpose": "Evaluates a jurisdiction against the OECD Pillar Two Transitional CbCR Safe Harbour (Dec 2022 Agreed Administrative Guidance): the de minimis test (CbCR revenue < EUR 10m AND profit before tax < EUR 1m, both versioned thresholds), the simplified ETR test (simplified covered taxes / profit before tax >= the fiscal-year transition rate -- 15% for 2023/2024, 16% for 2025, 17% for 2026, versioned rate table; auto-passes when profit before tax is non-positive since ETR is undefined), and the routine profits test (profit before tax <= the caller-supplied substance-based income exclusion amount). Safe harbour is met if ANY ONE of the three tests passes, in which case the jurisdiction's top-up tax is deemed zero. Returns each test as an independently gated pass/fail verdict with its own reasoning, plus the overall safe_harbour_met / deemed_zero_topup flags. Pure arithmetic threshold comparisons only -- elections, DTA characterization, and the SBIE amount itself are HUMAN JUDGMENT and enter only as policy_parameters; SBIE is not recomputed here (that is art-455's job). NaN-safe. Zero network, zero PII.",
  "control_description": "Evaluates a jurisdiction against the OECD Pillar Two Transitional CbCR Safe Harbour (Dec 2022 Agreed Administrative Guidance): the de minimis test (CbCR revenue < EUR 10m AND profit before tax < EUR 1m, both versioned thresholds), the simplified ETR test (simplified covered taxes / profit before tax >= the fiscal-year transition rate -- 15% for 2023/2024, 16% for 2025, 17% for 2026, versioned rate table; auto-passes when profit before tax is non-positive since ETR is undefined), and the routine profits test (profit before tax <= the caller-supplied substance-based income exclusion amount). Safe harbour is met if ANY ONE of the three tests passes, in which case the jurisdiction's top-up tax is deemed zero. Returns each test as an independently gated pass/fail verdict with its own reasoning, plus the overall safe_harbour_met / deemed_zero_topup flags. Pure arithmetic threshold comparisons only -- elections, DTA characterization, and the SBIE amount itself are HUMAN JUDGMENT and enter only as policy_parameters; SBIE is not recomputed here (that is art-455's job). NaN-safe. Zero network, zero PII.",
  "declared_inputs": [],
  "declared_outputs": [],
  "kernel_digest": "sha256:9dd9ae74b1d4edde67ba59bd862dc96cd7a0623011b3e59070bf5fd6ccbf3669",
  "trust_label": "independently verified -- zkVM execution proof (risc0/groth16-bn254)",
  "data_vintage": "2026-07-24",
  "last_validated": "2026-07-24",
  "conformance_fixtures_vendored": true,
  "compute_proof_ready": "ready",
  "wave": 74,
  "source_url": "https://ainumbers.co/chaingraph/art-456-globe-safe-harbour-tests.html",
  "generated_at": "2026-07-25T20:02:55.601Z"
}