Andersen Global
05 March 2026
OECD Pillar Two Side-by-Side Package: Planning Opportunities and Compliance Considerations for Multinational Enterprise Groups
The OECD Inclusive Framework released on January 5, 2026, adds significant additional Pillar Two administrative guidance that provides meaningful relief for many Multinational Enterprise (MNE) Groups, particularly those located in the United States. The guidance, referred to as the Side-by-Side (SBS) Package, introduces several new safe harbors and extends existing transitional relief.
