Markets

KPMG Analysis: Pillar Two Side-by-Side Package — Detailed Technical Breakdown

KPMG's 88-page technical analysis of the January 5, 2026 OECD package. The Substance-based Tax Incentive Safe Harbour is described as a halfway house. The Simplified ETR Safe Harbor will be welcomed by some businesses but others may see limited benefit.

KPMG·Jan 8, 2026·25 min read·assets.kpmg.com
KPMG: some businesses may prefer automating full GloBE computation vs SESH

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