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

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.