Engagements › Cobalt Bay Resorts › Pillar Two
Pillar Two
The global minimum tax of 15% (Dir. art. 3: 15%): whether Cobalt Bay Resorts is in scope, what is due in Cyprus and when, and where it meets the transfer pricing.
The global minimum tax: in scope or not, what is due, and the shipping exclusion.
In Scope? No, for 2025
Consolidated revenue of €750,000,000 or more in at least two of the four fiscal years before the tested year (Dir. 2022/2523 art. 2). Group consolidated accounts (invented) — to be confirmed with the client.
| Year | Revenue | Counts For 2025 |
|---|---|---|
| 2021 | €128,000,000 | Under |
| 2022 | €142,000,000 | Under |
| 2023 | €151,000,000 | Under |
| 2024 | €158,000,000 | Under |
| 2025 | €163,000,000 | outside the window |
None of the four years before 2025 are over the threshold.