In this episode, Bruno Aniceto da Silva, Senior Advisor and Kevin M. Jacobs, Managing Director, discuss potential policy implications of the Pillar Two Side-By-Side (SbS) system and other developments shaping the global tax landscape. This discussion wraps up our Pillar Two series by looking ahead to what’s on the horizon that could affect multinational corporations.

In this episode, Jayde Thompson and Hang Vo discuss what transaction readiness looks like in a Pillar Two world and how the global minimum tax is reshaping M&A activities. They explore key considerations across the transaction lifecycle—from early deal screening and threshold considerations through due diligence, structuring, effective tax rate modelling, and post-deal integration—while also reflecting on how the proposed OECD Side-by-Side Package may influence Pillar Two planning in an M&A context going forward.

In this episode, Shaun Lockhart and Carina Ngai discuss how Pillar Two is driving a fundamental shift in tax data, processes, and technology. They explore how organizations can integrate Pillar Two into the broader direct tax lifecycle, build a robust tax data architecture, and strengthen governance and controls, while using today’s compliance demands as a foundation for a future‑ready tax function.

Key topics covered include:

• Navigating the complex and granular data requirements under Pillar Two
• Integrating Pillar Two with the broader direct tax lifecycle, including tax provision and reporting
• Designing a tax‑enabled data architecture and centralized tax data platform
• Strengthening governance, controls, and data quality through technology and workflow
• Practical next steps and a phased roadmap toward a future‑ready tax function

In this episode, Jayde Thompson, Managing Director and Ed Raza, Senior Director break down the OECD’s Side‑by‑Side (SbS) Safe Harbour regime through a commercial, risk‑based lens and why it’s quickly becoming one of the most actionable opportunities in Pillar Two right now. Instead of treating this as “just another compliance simplification,” the discussion focuses on how tax leaders can use the latest package to identify structural relief, reduce unnecessary compliance effort, and prioritise the work that actually moves the ETR and Top‑up Tax outcome. They explore how to translate your Pillar Two profile into clear risk parameters across three practical fronts commercial, policy, and operational/data so organisations can move faster with confidence and avoid building overly complex processes in low‑risk areas.

In this episode, Tom Lobb and David Smyth discuss the UPE Safe Harbour announced as part of the Pillar Two side-by-side package in January 2026 and its significance within the evolving global minimum tax framework. The conversation explores the policy objectives behind the safe harbour, the issues it seeks to address, and the key criteria that must be met to qualify. They also examine which jurisdictions may be positioned to benefit and outline the practical implications for multinational groups navigating the complexities of Pillar Two implementation.

In this episode of the podcast series, Bryan Glanzberg and Cory Terry discuss the Side-by-Side Safe Harbour and its role within the Pillar 2 global minimum tax framework. The conversation explores how the safe harbour came to be, compares and contrasts what it means for US multinational companies vs. Non-US multinational companies, including compliance, reporting and due diligence considerations as well as potential future implications for US tax policy.

In this episode, Matt Andrew and Ruairi Lamb discuss the Substance‑Based Tax Incentive Safe Harbour and its role within the Pillar 2 global minimum tax framework. The conversation explores how the safe harbour is designed to preserve certain qualified tax incentives that are demonstrably linked to real economic activity, while also highlighting the practical implications for multinational groups and policymakers navigating the evolving Pillar 2 landscape.

Key topics covered include:

• How the Substance‑Based Tax Incentive Safe Harbour under Pillar Two aims to prevent GloBE top‑up tax from neutralising qualifying tax incentives.
• The key criteria for incentives to qualify—general availability and a clear link to local economic substance such as payroll and tangible assets.
• Treatment of refundable and transferable tax credits, including elective approaches and substance‑based caps.
• Implications for multinationals and governments, particularly for investment decisions, effective tax rate modelling, and asset‑intensive versus IP‑light business models

• (00:00:00) - Understanding the Substance Based Tax Incentive Safe Harbour

In this episode, Jordan Gill, International Tax Director, discusses what the extension to the pre-existing Transitional CbCR Safe Harbours means to Multinational Groups and what benefits this may have in providing technical and practical simplifications.