OECD Releases Pillar Two Side-by-Side Package: What It Means for Global Tax Planning
On January 5, 2026, the OECD agreed a landmark package modifying the 15% global minimum tax framework. The Side-by-Side Safe Harbour exempts US-parented MNEs from the Income Inclusion Rule and UTPR. Four new safe harbors introduced.
This briefing links to external reporting from A.O. Shearman. Stead Intelligence curates verified third-party sources for global mobility professionals and applicants.
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