New Publication: Implementing the OECD Side-by-Side Package

Our partner Jelena Mihić has published an article in International Tax Review examining the practical implications of the OECD’s side-by-side consolidation package for multinational enterprises.

The article, “Implementing the OECD side-by-side package: what MNEs must do now,” addresses the critical shift from theoretical Pillar Two modelling to compliance-driven execution as companies enter the 2026/2027 reporting cycles.

Key topics covered include computational adjustments to effective tax rate calculations, safe harbour alignment, data system requirements, and sector-specific implementation challenges for manufacturing, digital, and pharmaceutical companies. The article also provides a practical implementation roadmap and highlights common pitfalls tax teams should avoid, including the critical distinction between local QDMTTs and GloBE rules.

As tax departments transition from understanding policy to building execution systems, this guidance offers actionable steps for ensuring compliance and avoiding reconciliation discrepancies, double taxation, and audit vulnerabilities.

Read the full article: International Tax Review