Oecd Inclusive Framework Reaches Agreement On Pillar Two "Side-By-Side" Package

The year has begun with important developments in the international tax landscape, as countries participating in the OECD Inclusive Framework reached agreement on a package of measures reshaping the operation of Pillar Two (the Global Anti-Base Erosion, or "GloBE," rules). The "Side-by-Side Package,"¹ announced on January 5, introduces a series of safe harbors and simplification measures intended to reduce compliance burdens and better coordinate the interaction between domestic tax systems and the global minimum tax framework.

The package includes a Simplified Effective Tax Rate ("ETR") Safe Harbor, an extension of the Transitional Country-by-Country ("CbC") Reporting Safe Harbor, a Substance-based Tax Incentive Safe Harbor, and a Side-by-Side ("SbS") System.