How the Pillar 2 ‘side-by-side’ approach may work

The “side-by-side” approach would provide for the coexistence of the US system and the Pillar 2 system and would not seek to undermine Pillar 2.

The G7, comprising Canada, France, Germany, Italy, Japan, the United Kingdom and the United States, released a statement which outlines a shared understanding of a "side-by-side" solution to US concerns on Pillar 2. Factors leading to the Statement The Statement notes that the G7 discussions were informed by: proposed changes to the international tax system in the United States based on a Senate amendment of the One Big Beautiful Bill Act (OBBBA); the subsequent removal of Section 899 ...

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Authors: Grant Wardell-Johnson, Alia Lum

Published Date: 02 July 2025