Global minimum tax — OECD agrees on side-by-side system

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The OECD announced that the OECD/G20 Inclusive Framework on BEPS has reached agreement on key elements of a “side-by-side” package.

The OECD/G20 Inclusive Framework has reached agreement on the “side-by-side” package.

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08 January 2026

The "side-by-side system" is intended to preserve the global progress to implement rules to ensure large multinational enterprises (MNEs) pay a minimum rate of tax under the OECD Pillar Two framework, while also addressing U.S. concerns about these rules. Under this approach, U.S.-parented groups would be exempt from certain Pillar Two rules on the basis they are already subject to U.S. minimum tax rules.

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Global Minimum Tax — OECD Agrees on Side-by-Side System