EMEA Dbriefs - Update on latest Pillar Two developments: Side-by-Side package

On 5 January 2026, the OECD Inclusive Framework released a ‘Side-by-Side package’ in relation to the global minimum tax rules (‘Pillar Two’). The package covers a number of new or extended safe harbours. But what do the latest developments mean for your organisation and approach to Pillar Two compliance? We’ll discuss the:

• new permanent simplified effective tax rate safe-harbour;
• temporary extension of the transitional country-by-country safe harbour; 
• new substance-based tax incentive safe harbour;
• side-by-side system, including a side-by-side safe harbour and a UPE safe harbour, which will allow the US tax regime to sit alongside Pillar Two.

This webinar will enable you to keep up-to-date with this area as it develops over the course of 2026.