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Pillar Two: OECD Side-by-Side (SbS) Package

On 5 January 2026, the OECD/G20 Inclusive Framework (147 jurisdictions) agreed a way forward on Pillar Two and published the Side-by-Side (SbS) Package. The package introduces targeted simplifications and new safe harbours, while reaffirming QDMTTs as the primary mechanism for protecting domestic tax bases, changes that may materially affect Pillar Two compliance and cash tax…

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