News & Analysis as of

Organization for Economic Co-operation and Development

Mayer Brown

OECD Pillar Two Side-by-Side System and New Safe Harbors

Mayer Brown on

On January 5, 2026, the Organisation for Economic Co-operation and Development (“OECD”) announced that the Inclusive Framework on Base Erosion and Profit Shifting agreed to a new package of administrative guidance (the...more

Holland & Knight LLP

OECD Pillar Two Side-by-Side Safe Harbor Package: Technical Review and Implications

Holland & Knight LLP on

The Organisation for Economic Co-operation and Development (OECD)/G20 Inclusive Framework (Inclusive Framework) on January 5, 2026, released its Side-by-Side (SbS) Safe Harbor package (SbS Package) to streamline Pillar Two's...more

Eversheds Sutherland (US) LLP

Tax Bytes: Week of January 12, 2026

Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more

DLA Piper

OECD releases Pillar Two Side-by-Side package: Key tax takeaways for businesses

DLA Piper on

The Organisation for Economic Co-operation and Development (OECD) recently released its highly anticipated Side-by-Side (SbS) package, marking a significant step in alleviating the application of the global minimum tax rules...more

White & Case LLP

Mining & metals 2026: Adapting to a policy-driven business cycle

White & Case LLP on

In 2025, geopolitics drove events and investment in the mining & metals sector. The unprecedented degree of uncertainty, led by rapidly changing policies in the US and China, shifted markets into a deal cycle driven by...more

Eversheds Sutherland (US) LLP

What a relief: OECD releases Pillar Two Side-by-Side Package

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 extends and introduces new...more

Skadden, Arps, Slate, Meagher & Flom LLP

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 the Pillar Two Global...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, Jan. 2026

OECD Announces Pillar Two Agreement: On Monday, the Organisation of Economic Co-operation and Development (OECD) announced a “Side-by-Side package” under the Pillar Two global minimum tax regime that reflects the June 2025...more

Paul Hastings LLP

OECD Agreement on Pillar Two: UK Government Sets Out Next Steps

Paul Hastings LLP on

In the wake of the OECD’s announcement on 5 January 2026 that it has agreed a “side by side” package to address U.S. concerns about “Pillar Two” (the rules imposing a 15% minimum corporate income tax), the U.K. government has...more

Ropes & Gray LLP

Private Capital: UK and EU Tax Themes and Initiatives to Be Aware of in 2026

Ropes & Gray LLP on

As the private capital industry looks ahead to 2026, the UK and EU tax landscape is set to present both challenges and opportunities. Recent developments and ongoing policy initiatives will have a direct impact on deal...more

Carey Olsen

The Crypto-Asset Reporting Framework and its implications for the Cayman Islands

Carey Olsen on

The Crypto-Asset Reporting Framework (“CARF”) is an international tax transparency standard developed by the Organisation for Economic Co-operation and Development (“OECD”). Introduced as an extension of the existing Common...more

Bergeson & Campbell, P.C.

OECD Publishes Policy Brief on Financing Instruments and Policy Levers to Harness Biomanufacturing for Climate, Biodiversity, and...

On December 2, 2025, the Organisation for Economic Co-operation and Development (OECD) published a policy brief entitled “Financing instruments and policy levers to harness biomanufacturing for climate, biodiversity and...more

A&O Shearman

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

A&O Shearman on

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 Pillar Two) while...more

Walkers

OECDs Crypto Asset Reporting Framework: What does this mean for Guernsey

Walkers on

Guernsey has moved quickly to implement the OECD’s Crypto-Asset Reporting Framework (CARF), marking a further significant development for the island’s financial and digital asset sectors. Regulations implementing CARF in...more

Bergeson & Campbell, P.C.

OECD Will Hold Webinar on January 15, 2026, on “From Production to End-of-Life: Understanding Fluoropolymers across the Life...

On January 15, 2026, the Organisation for Economic Co-operation and Development (OECD) will hold a webinar on its recent report, Synthesis Report on Understanding Fluoropolymers and Their Life Cycle. As reported in our...more

Bergeson & Campbell, P.C.

OECD Publishes Report on Identification of Exposure Metrics for Use in Evaluation of Inhalation Exposure to Nano-Objects and Their...

On December 12, 2025, the Organisation for Economic Co-operation and Development published a report entitled The Identification of Exposure Metrics for Use in Evaluation of Inhalation Exposure to Nano-Objects and their...more

Cadwalader, Wickersham & Taft LLP

Plenty at Stake in a Budget of Two Halves

As part of the UK Budget measures on 26 November 2025, two announcements were made by the UK Government concerning, respectively, the tax reporting of cryptoassets and the taxation of decentralised finance (“DeFi”) involving...more

DLA Piper

Tax in a Time of Transition: Navigating the Shifting Global Tax Policy Landscape

DLA Piper on

The global tax environment is becoming increasingly complex and interconnected, with significant implications for compliance, risk management, and strategic planning. Recent developments such as the OECD’s Pillar Two...more

Bergeson & Campbell, P.C.

OECD Publishes Synthesis Report on Understanding Fluoropolymers and Their Life Cycle

On November 14, 2025, the Organisation for Economic Co-operation and Development (OECD) published a report entitled Synthesis Report on Understanding Fluoropolymers and Their Life Cycle. The report provides a synthesis of the...more

Ius Laboris

New OECD Guidance on ‘Permanent Establishment’ and Overseas Employees

Ius Laboris on

The issue of whether an individual employed in one jurisdiction but working in another creates a taxable presence (a “permanent establishment” or “PE”) in the country in which the individual is working is a fundamental...more

Eversheds Sutherland (US) LLP

Tax Bytes: Week of December 8, 2025

Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to...more

DLA Piper

Singapore’s 8th Edition Transfer Pricing Guidelines: Comprehensive Updates and Strategic Implications for Businesses

DLA Piper on

Introduction - The Inland Revenue Authority of Singapore (IRAS) issued the Eighth Edition of its Transfer Pricing Guidelines (TPG8) on 19 November 2025. The new edition refines several areas of the earlier guidance1 and...more

DLA Piper

OECD’s 2025 Model Tax Convention update: What it means for multinationals

DLA Piper on

The OECD’s 2025 update to the Model Tax Convention marks a significant shift in how tax treaties address cross border remote work, natural resource activities and a number of important technical issues around transfer...more

Barnea Jaffa Lande & Co.

Court Ruling on Valuing Restructuring Transactions: Tax Gross-Up, Holdback, and Secondary Adjustments

Barnea Jaffa Lande & Co. on

Multinational companies in Israel that carry out acquisition, sale or restructuring transactions sometimes encounter complex issues relating to transfer prices. According to Israeli law, transactions between related entities...more

Conyers

Country by Country Reporting (CbCR) – Re-registration Required by 30 November 2025

Conyers on

All Multi-National Enterprise (MNE) Groups that have Cayman Constituent Entities for purposes of the Country-by-Country Reporting (CbCR) Regime will need to complete a one-off re-registration on the new DITC CbCR Portal by 30...more

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