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ARTICLE · 16 DECEMBER 2025

The EU Solve For Pillar Two – Can They Really Do That?

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Over the coming twelve months, the EU must confront some challenging Pillar Two issues, including addressing the G7 ‘side-by-side' deal on Pillar Two before the end of December...

IrelandTax
Olivia Long
Olivia Long
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Over the coming twelve months, the EU must confront some challenging Pillar Two issues, including addressing the G7 'side-by-side' deal on Pillar Two before the end of December and defending legal challenges to the EU implementation of Pillar Two in the Court of Justice ("CJEU") later in 2026.

These issues are unique to the EU legal system and will have to be tackled in tandem with the broader politics inherent in the on-going revision of Pillar Two. This briefing addresses the current state of the 'side-by-side' workstream at EU-level and our next briefing will focus on the EU legal challenges to Pillar Two.

OECD negotiation of the side-by-side solution

The current OECD negotiations on Pillar Two are focussed on the implementation of the 'side-by-side' deal announced by the G7 countries in June 2025. Under this deal, the G7 committed to work at OECD-level with countries that have implemented Pillar Two (including many EU Member States) to deliver: (i) an

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