Will Pillar Two Prosper Despite the US Side-by-Side Arrangement?

Daniele Majorana

doi:10.59403/acb42w

August 6, 2026Bulletin for international taxation

Will Pillar Two Prosper Despite the US Side-by-Side Arrangement?

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Key Points

This article explores whether the US exemptions from Pillar Two's rules damage its overall coherence.
Employed doctrinal and structural analysis
Investigated exemptions granted to US-parented groups
Analyzed implications for Pillar Two's universality
US exemptions entrench fragmentation within Pillar Two
Asymmetries undermine the intended coherence of the framework
The accommodation appears to be a permanent fixture in the regulatory landscape

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Implication

Doctrinal analysis assesses the impact of US exemptions on Pillar Two's coherence, indicating potential fragmentation.

Abstract

The OECD's Side-by-Side Package exempts US-parented groups from Pillar Two's Income Inclusion Rule and Undertaxed Profits Rule despite a 14% US minimum tax. Employing doctrinal and structural analysis, this article asks whether the resulting asymmetries undermine Pillar Two's coherence, concluding that the accommodation is permanent, entrenching fragmentation without achieving universality.

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Cite This Study

Daniele Majorana (2026) studied this question.

synapsesocial.com/papers/6a76dacaf12abadc79815587 https://doi.org/10.59403/acb42w

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Will Pillar Two Prosper Despite the US Side-by-Side Arrangement?

Key Points

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Implication

Abstract

Discussion

Cite This Study

Will Pillar Two Prosper Despite the US Side-by-Side Arrangement?

Key Points

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Implication

Abstract

Discussion

Cite This Study

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