JD Supra

OECD Publishes Pillar Two Global Minimum Tax Safe Harbor, Benefitting MNE Groups With Ultimate Parent Entities Located in the U.S.

On January 5, 2026, the Organisation for Economic Co-operation and Development (OECD) released a long-awaited package of administrative guidance which introduces a number of new safe harbors within ...
JD Supra

The Side-By-Side Package And The Global Minimum Tax: What You Need To Know

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 ...