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

In the first of a two-part series on capital v revenue in R&D, Jayne Stokes explores these key concepts and where UK companies need to tread carefully
Magnus Pantzar is set to join as managing director after spending nearly a decade as EQT’s global head of tax
The OECD’s project was up for debate as Matt Williams spoke to ITR following BDO’s tax strategist survey, which uncovered increased complexity and costs among multinationals
Sponsored by Deloitte
Sameer Nurmohamed, partner, Deloitte Legal Canada
Sponsored by Deloitte
George Ankomah, partner, Tax & Regulatory Services, Deloitte Africa (Ghana)
The recent spree of firm mergers and acquisitions proves that geographic scale is the name of the game
The big four spin-off firm becomes Taxand’s second UK member; in other news, Haynes Boone launched a UK tax practice
Sponsored by Deloitte Luxembourg
Jean-Michel Henry and Mona El-Begawi of Deloitte Luxembourg examine the complexities created by timing differences in Luxembourg, EU, and OECD tax regimes
Stephanie Pantelidaki’s economic expertise will give Norton Rose Fulbright’s other teams ‘extra firepower,’ she says
Sponsored by MFA Legal & Tech
Samuel Fernandes de Almeida of MFA Legal & Tech assesses whether Portugal’s 7.5% surcharge on non-residents aligns with the EU’s free movement of capital principle and passes the proportionality test
Gift this article