Description

The newly approved Side by Side (SbS) package of the Organisation for Economic Co-operation and Development (OECD) marks a major step forward in the coordinated operation of the global minimum tax (Pillar Two).

This session examines how the SbS package introduces:

- New safe harbors

- Simplified effective tax rate calculations

- A notable U.S. exemption designed to ease compliance burdens for multinational enterprises

Participants will gain practical insights into how these changes affect U.S. multinationals, what the safe harbors mean in practice, and how tax leaders can strategically position their organizations to:

- Reduce risk

- Enhance certainty

- Prepare for the future in a rapidly evolving international tax environment

Instructor: Cory Perry,Ryan Bowen,Phil Ramstetter,Chloe Fox

Target Audience

CPAs, international practitioners, large firms, medium firms

Course Objectives

· Differentiate the key components of the OECD Side by Side package, including new safe harbors for Qualified SbS Regimes, substance-based non-refundable tax incentives, and the simplified effective tax rate (ETR) rules.

· Determine the scope and implications of the U.S. exemption, and how it affects multinational groups headquartered or operating in the United States.

· Determine how the SbS safe harbors reduce compliance complexity under Pillar Two and where they may provide relief for affected entities.

· Distinguish strategic tax considerations, including how to leverage simplified rules while preparing for global minimum tax implementation.

· Analyze operational impacts, such as data requirements, reporting adjustments, and cross-jurisdictional coordination.

· Apply insights to strengthen internal readiness and reduce uncertainty in global minimum tax compliance.

Subjects

· Overview of the OECD Side by Side (SbS) package

· Understanding the U.S. exemption

· How SbS safe harbors reduce compliance complexity

· Strategic tax planning under the SbS framework

· Operational and data impacts

· Enhancing internal readiness

Prerequisites

Basic understanding of international taxation