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

Death, taxes and Deloitte hoovering up trophies at an ITR awards night. Isn’t that the saying?
AI, pillar two and joint audits could define the next era of tax controversy, says Baker McKenzie tax partner Ariane Calloud
Gregor McMillan of Howden explains how insurance-backed financing can help businesses and funds unlock liquidity from tax receivables and other contingent claims
The arrival of Alex Anderson swiftly follows that of funds tax specialist Stuart Alter and suggests the Tier 3-ranked firm has higher ambitions
One of the two appointments is EY’s Gordon McIntosh, who becomes the big four firm’s second senior tax departure in September
Balson's move from a Tier 1 practice to a Tier 3 competitor looks counterintuitive. The market data suggests it is anything but
Awards
It was another banner year for Deloitte, which picked up more awards than any other firm at a gala ceremony held at The Londoner in Leicester Square
The big four firm has been embroiled in a scandal over partners’ misuse of confidential board papers to pitch for and win corporate audits for Westpac and Dexus
Drawing on lessons from the PepsiCo case, tax lawyer Paul McNab explains why the ATO's latest royalty guidance should concern multinationals well beyond the technology sector
As pillar two exposes the limits of fragmented tax processes, organisations are rethinking their operating models to create the trusted data foundations that AI demands
Gift this article