GILTI Conscience Podcast | Navigating Pillar Two: Side-by-Side, Safe Harbors and the Future of Global Tax Cooperation
GILTI Conscience Podcast | The UK Tackles Pillars One and Two
The UK Prudential Regulation Authority (PRA) has published consultation paper CP5/26 proposing reforms to modernise the existing prudential liquidity framework, taking into account advances in digital banking, payments and...more
On this episode of "GILTI Conscience," Skadden attorneys David Farhat, Patrick O'Gara, Loren Ponds and Stefane Victor are joined by guest Pascal Saint-Amans, founder and CEO of Saint-Amans Global Advisory and former director...more
Consumer credit is one of the most closely watched topics in 2026, as businesses and regulators prepare for the full implementation of the revised EU Consumer Credit Directive (CCD II) next November....more
The Organisation for Economic Co-operation and Development (OECD) issued a side-by-side package (the package) on January 5, 2026, resolving many of the concerns that U.S.-parented multinational companies had with the Pillar...more
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
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
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
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
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
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
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
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
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
The European Central Bank (ECB) has announced it will conduct a geopolitical risk reverse stress test on 110 directly supervised banks in the Single Supervisory Mechanism in 2026. In a reverse stress test, a pre-defined...more
Migration, redomiciliation, continuation - the process which has many names is increasing in popularity. Guernsey has experienced a notable increase in the inward migration of corporate vehicles from other jurisdictions....more
We present to you the Summer 2025 edition of the Asia Tax Bulletin. It contains tax developments in Asia on a host of topics, such as Hong Kong’s and Japan’s tax legislation to implement the Minimum Global Tax (also referred...more
The United States has agreed with other G7 members to remove the section 899 protective tax measures from One Big Beautiful Bill in exchange for an agreement to exclude U.S. headed groups from major aspects of the OECD global...more
The implementation of the Organisation for Economic Co-operation and Development’s (OECD’s) Pillar II rules in Europe, and in the Luxembourg law on 22 December 2023 (the Pillar II Law) in particular, has been a major...more
The Prudential Regulation Authority (PRA) published a policy statement (PS2/25) on streamlining firm-specific capital communications which simplifies the content and process of the firm-specific capital communications used to...more
As part of its “America First Trade Policy,” the White House is exploring an arcane IRS provision that allows the United States to double the tax rates of foreign companies and individuals....more
The Prudential Regulation Authority has announced that, in consultation with HM Treasury, it has decided to delay the implementation of Basel 3.1 in the U.K. by one year until January 1, 2027. The PRA explains that it has...more
Rewriting the international tax framework to introduce a Global Minimum Tax (also known as Pillar Two) was always going to be a battle against the odds. However, despite various obstacles and setbacks, we closed out 2024 with...more
President-elect Donald Trump is set to return to the White House with Republicans narrowly securing both the US Senate and the US House of Representatives. Having control of both chambers positions the party well to pursue...more
We recently hosted a webinar on Pillar Two and its practical impact on joint ventures (JVs). Our key takeaways are set out below. Introduction to Pillar Two - Pillar Two, also known as the global minimum tax, is an...more
On August 6, 2024, the U.S. Treasury Department (“Treasury”) issued proposed regulations under section 1503 (the “Proposed Regulations”) that address the interaction between the dual consolidated loss (“DCL”) rules and the...more