Newsalert | Tax 16/01/2026

On 5 January, the OECD published the “Global Anti-Base Erosion Model Rules (Pillar Two), Side-by-Side Package”, as agreed by the members of the Inclusive Framework on BEPS. The Package addresses U.S. concerns regarding the global minimum tax while preserving the overall coherence of the system. Its content was also presented during an OECD Secretariat webcast on 13 January 2026.

In the latest newsalert, Chiomenti Professionals analysed the key elements of the Package, which introduces a Side-by-Side Safe Harbor, a permanent UPE Safe Harbor, and substantially changes the rules in relation to tax incentives, with the introduction of a new Substance-Based Tax Incentives (SBTI) Safe Harbor and a permanent Simplified ETR Safe Harbor.