OECD’s ‘Side by Side’ Package Paves Way for Global Pillar Two Tax Implementation; India’s 2026 Budget in Focus

By Niranjan Govindekar, Partner – Corporate Tax, Tax & Regulatory Advisory, BDO India

“The “side by side” package released by OECD, is a significant initiative for implementation of Pillar Two framework through a common approach, simplicity, and certainty. Once key elements of safe harbours contained in this Package are incorporated into domestic legislation by respective jurisdictions, it is expected to provide a stable international tax system. Large MNEs, operating in jurisdictions where GloBE Rules have already been implemented, should review these new safe harbours and evaluate potential impact on its global minimum tax liability. India is yet to adopt Pillar Two framework; it would be interesting to watch whether Union Budget 2026 unveils a formal legislation on Pillar Two.”