Agreement reached on Pillar Two side-by-side package

The 88-page side-by-side package of documents modifies key elements of the Pillar Two global minimum tax framework.

The Organisation for Economic Co-operation and Development (OECD) has announced that the OECD/G20 Inclusive Framework on base erosion and profit shifting (BEPS) has reached agreement on key elements of a 'side-by-side' package allowing for continued coordinated operation of Pillar Two global minimum tax arrangements. According to the OECD release, the comprehensive side-by-side package preserves the gains achieved so far in the global minimum tax framework and protects the ability for all ju...

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Authors: Conrad Turley, Alia Lum

Published Date: 23 January 2026