The OECD’s Side-by-Side Package: Stabilizing Pillar Two or the Beginning of Fragmentation?
The global minimum tax was never going to be implemented without political compromise. What was unexpected, however, was how central that compromise would become to the future of the OECD/G20 Inclusive Framework itself. The OECD’s Side-by-Side Package, released on 5 January 2026, marks a decisive moment in the evolution of Pillar Two(GloBE)—one that raises fundamental questions about global tax harmonization,… Continue reading "The OECD’s Side-by-Side Package: Stabilizing Pillar Two or the Beginning of Fragmentation?"














