International: Pillar Two — Die Another Day

In brief

In their article "Pillar Two: No Time to Die, Die Another Day, You Only Live Twice?", Ethan Kroll and Miles Humphry discuss the Organization for Economic Co-operation and Development's (OECD’s) new Side‑by‑Side Package, which introduces long‑awaited safe harbors designed to ease Pillar Two compliance. US-parented multinationals benefit most from the Side‑by‑Side Safe Harbor, which effectively eliminates Income Inclusion Rule (IIR) and Undertaxed Payments Rule (UTPR) Top‑up Tax exposure starting in 2026. A new Simplified Effective Tax Rate (ETR) Safe Harbor and new treatment for substance‑based tax incentives, also offer partial relief for other groups. The article was published in the Tax Management International Journal on 14 January 2026.

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Reproduced with permission from Tax Management International Journal, 14 January 2026. Copyright @ 2026 by Bloomberg Industry Group, Inc. (800-372-1033).