On January 5, 2026, the OECD Inclusive Framework
(IF) on Base Erosion and Profit Shifting
(BEPS) released the highly anticipated
Side-by-Side (SbS) package1.
1. Introduction
The SbS package responds to the G7's
call2 to reduce compliance burdens for in-scope
multinational enterprises (MNE Groups) through
simplification measures and to ensure fair treatment of
substance-based tax incentives.
The SbS package introduces four new safe harbours and
extends the Transitional CbCR Safe Harbour
(TSH) by one year. The new safe harbours address
three key areas:
- SbS System: The SbS Safe Harbour and the Ultimate Parent Entity
(UPE) Safe Harbour
- Tax Incentives: The Substance-Based Tax Incentives
(SBTI) Safe Harbour
