While tax is commonly regarded as one of two certainties in life, many questions remain concerning pillar two. Are there downsides to the side-by-side package announced in January 2026? Is the new simplified effective tax rate safe harbour truly simpler in practice? Are further OECD measures on the horizon?
An ITR podcast recorded in partnership with Deloitte provides an inside track on the key pillar two issues as the following speakers explore the perspectives of clients, governments, and the OECD:
Chad Hungerford, a partner in Deloitte Tax LLP’s international tax practice and Deloitte’s global pillar two leader; and
Alison Lobb, a partner at Deloitte UK who specialises in international tax and policy.
From a US standpoint, Hungerford explains that the side-by-side agreement has helped ease political uncertainty and reduced the likelihood of top‑up tax for many, but also introduces a new layer of operational complexity. Lobb, meanwhile, believes that the measures represent just the “start of the simplification journey” and cites the OECD’s Amsterdam Dialogue in discussing the possibility of further reforms.
The conversation also examines the relationship between the new simplified effective tax rate and the transitional country-by-country reporting safe harbour, and the data and systems challenges confronting taxpayers and governments. For tax practitioners facing evolving compliance requirements, Hungerford says, “there’s a lot of work headed their way”. That much, at least, seems certain.
