On January 5, 2026, the OECD published the Global Anti-Base Erosion Model Rules (Pillar Two), Side-by-Side Package (side-by-side package), following months of negotiations. The side-by-side package ...
Following months of negotiations and speculation, the OECD released a “side-by-side” package on January 5, 2026, which is intended to address U.S. concerns about the global minimum tax (also known as ...