What a Relief: OECD Releases Pillar Two Side-by-Side Package

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What a Relief: OECD Releases Pillar Two Side-by-Side Package

Journal of International Taxation

April 01, 2026

United StatesUnited KingdomNetherlands
United StatesUnited KingdomNetherlands
United StatesUnited KingdomNetherlands

In an article published in the Journal of International Taxation, Eversheds Sutherland attorneys Megan Hall, Ben Jones, and Zoya Zalmai analyze the OECD’s newly released Pillar Two Side-by-Side Package and its implications for multinational enterprises. The authors explain how the package expands and introduces new safe harbors under the Global Anti Base Erosion (GloBE) rules, providing meaningful relief – particularly for U.S. headquartered companies – while emphasizing that companies must reassess Pillar Two planning and compliance strategies for 2026 and beyond.

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meganhall@eversheds-sutherland.com

Megan K. Hall

Partner

Washington, DC, United States

benjones@eversheds-sutherland.com

Ben Jones

Partner

United Kingdom

zoyazalmai@eversheds-sutherland.com

Zoya Zalmai

Partner

Amsterdam, Netherlands

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