OECD Pillar Two: Tax implications for US multinationals

The OECD’s January 2026 Administrative Guidance on Pillar Two introduces new safe harbor provisions that could significantly affect how US multinationals are taxed globally. This episode breaks down the key provisions and their accounting and financial reporting implications. In this episode, we discuss: 1:13 – Background on Pillar Two and core concepts 6:57 – Overview of the OECD Administrative Guidance 17:10 – Criteria for the Side-by-Side Safe Harbor 21:46 – Ultimate Parent ...