Understanding the UPE Safe Harbour

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.