OECD Side-by-Side Agreement Statement
- Foilsithe: 5 Eanáir 2026
- An t-eolas is déanaí: 5 Eanáir 2026
A Side-by-Side Package in relation to Global Minimum Tax was approved and adopted by Members of the OECD / G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) on 5 January 2026. The package of documents was published on the OECD website earlier today.
The package delivers on the G7 ‘Statement on global minimum taxes’, and subsequent G20 Communiqué, which requested that the Inclusive Framework design a solution whereby the objectives of the Global Minimum Tax are preserved while developing a mechanism to allow for co-existence with the US tax system.
The Side-by-Side System Package as agreed delivers three main outcomes:
(1) Side-by-Side System, setting out rules to facilitate existing minimum tax regimes.
(2) Simplification measures; and
(3) Alignment of Substance-Based Tax Incentives.
The package aims to strike a balance that resolves the US concerns with the Global Minimum Tax, while preserving the original objectives of Pillar Two as set out in the October 2021, OECD Tax Agreement.
The package also provides for a time-bound stocktake exercise that commits the Inclusive Framework to a review of the Side-by-Side System in 2029. This will ensure that any risks or competitiveness issues that arise will be addressed in a timely manner. The stocktake will also be accompanied by an assessment by the European Commission on the implementation and effects of the Side-by-Side System and its impact on EU Competitiveness as outlined in the Commission statement provided at the ECOFIN meeting on 12 December.
The Tánaiste welcomes the certainty and stability that adoption of the Side-by-Side System Package by the Inclusive Framework delivers to stakeholders and tax administrations in relation to the international tax architecture and broader macroeconomic environment.
In addition to the immediate simplification benefits already set out in the documents, the package includes commitments to additional simplification measures to bring further material improvements for stakeholders in the near future.
Upon approval of the OECD / G20 Inclusive Framework on BEPS of the Side-by-Side System Package on Global Minimum Tax, An Tánaiste and Minister for Finance Simon Harris T.D. noted:
“As a member of the OECD/G20 Inclusive Framework on BEPS, Ireland joined the global consensus in agreeing a Side-by-Side system which acknowledges the robustness of both the US tax system and the global minimum tax, while preserving the original objectives of the OECD international tax agreement.”
“This package was carefully negotiated in response to the US’ concerns and the mandate that followed from the G7 and G20. Maintaining a stable international tax architecture is vital: firstly, to preserve the important gains we have made over the past decade or so in addressing base erosion and profit shifting, and secondly, to provide the clarity and certainty required by businesses and tax administrations who must implement these complex rules.”
“Ireland welcomes the commitment to continue work at the OECD on further simplification, in recognition of the compliance burden faced by those implementing the Global Minimum Tax rules and supports work to reduce the complexity of the framework. We also welcome the commitment from the European Commission to conduct an assessment on the implementation and effect of the package and its impact on EU competitiveness in due course”
Delivering this agreement at the Inclusive Framework is a strong signal, reinforcing our collective commitment to multilateralism and acknowledging its effectiveness in delivering a shared solution to a global challenge.