Podcast – Pillar two rule update: some good news, but real work ahead

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Podcast – Pillar two rule update: some good news, but real work ahead

Sponsored by

Sponsored_Firms_deloitte.png
article banner-640x360.png

Deloitte pillar two experts Chad Hungerford and Alison Lobb share their insights on the latest developments and practical issues that are emerging – and what may lie ahead

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.

more across site & shared bottom lb ros

More from across our site

Rolf van de Velde, dubbed ‘an expert chosen by experts’, is tasked with scaling Reptune’s self-service compliance offering
The newly combined firm brings together more than 3,500 practitioners across 52 offices, with flagship hubs in Seattle, London, Sydney and New York.
Building a transparent culture, prioritising internal promotions and being different from the big four are all key features of A&M Tax’s ambitious plans for India
ITR’s Indirect Tax Forum 2026 showed why harmonisation remains elusive, advisers must raise their game, and ‘everyone’s data is rubbish’
The firm’s board has reportedly asked Kevin Burrowes to continue until 2028 as the KPMG Australia scandal raises expectations of regulatory reform
A former Deloitte partner will lead the firm’s latest geographic expansion; in other news, Baker McKenzie added six tax lawyers to its partnership
The Fair Tax Mark now extends to domestic-only companies with turnover above €1m, with Thai travel operator Tripseed the first to be certified
A technology provider had to be educated on technical requirements by Joseph Ribkoff’s IT team, a tax manager at the company said
But businesses should remain flexible when choosing between internal and external resources to handle added ViDA complexity, ITR’s Indirect Tax forum also heard
Non-compliance from small businesses continues to account for most of the gap, HM Revenue and Customs revealed
Gift this article