The Organisation for Economic Co-operation and Development (OECD) has released a Side-by-Side administrative guidance package under the Pillar Two Global Anti-Base Erosion (GloBE) framework.
The guidance is designed to support the coordinated and consistent application of the GloBE rules across jurisdictions, with a particular focus on the practical operation of side-by-side regimes adopted by different implementing countries and regions. From an administrative perspective, the package addresses how overlapping or parallel Pillar Two systems are applied in practice, with the objective of reducing complexity and mitigating risks of duplication or inconsistency for multinational enterprise groups.
The package addresses a number of key administrative and safe harbour-related elements under Pillar Two, including:
- the operation of a simplified ETR safe harbour in later fiscal years;
- aspects of the transitional CbCR safe harbour, including its continued availability;
- administrative treatment of substance-based tax incentives; and
- the design and application of a side-by-side system for MNE groups subject to Pillar Two in multiple jurisdictions.
The guidance is particularly relevant for groups operating in jurisdictions that have implemented Pillar Two through different legislative or institutional approaches, including those aligned with regional frameworks. Both tax authorities and taxpayers are expected to rely on the package in navigating compliance, administration, and dispute-prevention considerations under the global minimum tax.
The guidance is available on the OECD’s Pillar Two administrative guidance page: [link].
For a more detailed analysis of the guidance, or a review of how it may impact your company, please do not hesitate to contact our international tax experts; Jacques Malherbe and Rik Strauven.
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This newsletter does not constitute legal advice or a legal opinion. Please consult with a legal counsel before taking any action based on the information provided.