Side-by-Side: Simplifications for the global minimum tax

In practice, the implementation of the global minimum tax under Pillar Two is associated with significant administrative and interpretative complexity. The Side-by-Side package, approved at the beginning of 2026 within the OECD/G20 framework, responds to these challenges by introducing adjustments aimed at providing taxpayers with several possible simplifications, particularly in the initial years of application.

Ondřej Málek addresses the topic in his article for Právní prostor, where he outlines both the context of the package and its implications for multinational groups.

The changes primarily concern the calculation of the effective tax rate, the use of data from CbCR reporting, and the treatment of tax incentives. In certain situations, the new rules may reduce administrative burdens and provide greater certainty in the application of Pillar Two; however, they also require an individual assessment of their impact.

The full article is available here.