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

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,

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

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

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.

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Jamaica To Hire Baker & MacKenzie As Financial Centre Consultants

By: Ainsley Brown Jamaica is set to hire global legal giant Baker & MacKenzie (Baker) as its consultant on its new International Financial Centre (IFC). The deal, the details of which are still immerging, is subject to Cabinet approval and would see Baker advising the Jamaican government on the best ways to implement the IFC in this current economic climate. 

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Liechtenstein And The UK Enter Tax Info Sharing Agreement

By: Ainsley Brown It has been reported in the Times that ¨up to 5, 000 British investors have an estimated £3 billion stashed away in secret accounts in Liechtenstein. It is a good thing then, well good from the perspective of HM Revenue & Customs (HMRC), that Liechtenstein and the UK Government have reached an agreement on the sharing of

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The Swiss Banking Business Model Faces Realignment

By: Ainsley Brown The world economic down turn has had many knock on effects, many of which unexpected. It seems that bad times has the uncanny effect of making the once unthinkable, unsayable and undoable all very much possible. The Swiss banking model can be best characterized with one word: Secrecy. This don’t ask don’t tell attitude is more than

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Cayman Islands and Nordic Counties Agree To Share Information On Taxes

By: Ainsley Brown The between tax evasion and legitimate tax planning is a fine one indeed. This line is now set to get even thinner. How? Before I get into the specifics of this a little background is in order. The issues of cross-border taxation are as old as commerce itself, as are the issues of tax evasion and tax

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