On 5 January 2026, the OECD/G20 Inclusive Framework on BEPS released a comprehensive package of administrative guidance on the Pillar Two Global Anti-Base Erosion (GloBE) rules, including the Side-by-Side (“SbS”) system.

This package introduces simplifications and safe harbours to enhance certainty, reduce compliance burdens, and enable coexistence with certain domestic regimes [notably the US Global Intangible Low-Taxed Income (GILTI) rules].

Click the link for Christine Schwarzl’s overview: OECD releases administrative guidance (including the Side-by-Side package)