Global Anti-Base Erosion Model Rules (Pillar 2), Side-by-Side: Inclusive Framework on BEPS (OECD)

Reuven Avi-Yonah

doi:10.1017/ilm.2026.10162

July 28, 2026International Legal MaterialsOpen Access

Global Anti-Base Erosion Model Rules (Pillar 2), Side-by-Side: Inclusive Framework on BEPS (OECD)

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Key Points

This evaluation aims to assess the implications of the SBS rule on the global minimum tax under Pillar 2.
Evaluative analysis of the OECD SBS Package adopted in January 2026.
Examination of the applicability of Pillar 2 tax rules to U.S. multinationals.
Pillar 2 rules do not apply to U.S. multinationals under the SBS framework, impacting global tax strategies.
Potential shifts in multinational corporate tax obligations arising from the new regulations.

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Implication

This analysis evaluates the SBS rule's impact on Pillar 2 in U.S. multinationals, suggesting significant implications.

Abstract

Under the Side-by-Side (SBS) Package adopted by the OECD in January 2026, the global minimum tax of Pillar 2 of the Base Erosion and Profit Shifting (BEPS) rules will not apply to U.S. multinationals. This introductory note evaluates the SBS rule and its effects on Pillar 2.

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Reuven Avi-Yonah (2026) studied this question.

synapsesocial.com/papers/6a6af57860e2b924d3ea1c70 https://doi.org/10.1017/ilm.2026.10162

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Global Anti-Base Erosion Model Rules (Pillar 2), Side-by-Side: Inclusive Framework on BEPS (OECD)

Key Points

Ask about this paper

Implication

Abstract

Discussion

Cite This Study

Global Anti-Base Erosion Model Rules (Pillar 2), Side-by-Side: Inclusive Framework on BEPS (OECD)

Key Points

Ask about this paper

Implication

Abstract

Discussion

Cite This Study

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