international taxation

The OECD’s Side-by-Side Package: Stabilizing Pillar Two or the Beginning of Fragmentation?

January 26, 2026 Ainsley Brown Leave a comment

The global minimum tax was never going to be implemented without political compromise. What was unexpected, however, was how central that compromise would become to the future of the OECD/G20 Inclusive Framework itself. The OECD’s Side-by-Side Package, released on 5 January 2026, marks a decisive moment in the evolution of Pillar Two(GloBE)—one that raises fundamental questions about global tax harmonization,

International, Tax, Treaty

Understanding the OECD Inclusive Framework, Pillar Two, and the Architecture of the Global Minimum Tax

January 22, 2026 Ainsley Brown Leave a comment

International corporate taxation is undergoing its most consequential reform in nearly a century. At the center of this transformation is the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS)—a multilateral platform designed to modernize global tax rules for an economy defined by digitalization, mobility of capital, and highly integrated multinational enterprises (MNEs). These reforms are not merely technical.

Commercial Awareness, Government Policy, International, Investment, Tax, Treaty