Pillar Two on CompPress | Transfer Pricing Resources

Germany Issues Draft Regulation Listing Jurisdictions With Qualifying Pillar Two Status

Wed, 08 Apr 2026 00:00:00 +0000

On April 8, 2026, Germany issued a Draft Regulation including a list of jurisdictions that hold qualifying status for the purposes of the Income Inclusion Rule (IIR), the Undertaxed Profits Rule (UTPR), the Qualified Domestic Minimum Top-up Tax (QDMTT) and the QDMTT Safe Harbour under the German implementation of the OECD Pillar Two GloBE rules.

The list serves a practical administrative function: under the GloBE framework, the operation of the IIR, UTPR and QDMTT depends on whether the relevant jurisdiction’s domestic regime has been recognized as qualifying. Germany’s Draft Regulation provides authoritative guidance to German-headquartered MNE groups and to German subsidiaries of foreign MNE groups on which jurisdictions can be relied upon for QDMTT Safe Harbour purposes and which jurisdictions’ IIR and UTPR will be respected.

Switzerland Issues Communications Implementing OECD January 2025 and 2026 Administrative Guidance

Tue, 07 Apr 2026 00:00:00 +0000

The Swiss Federal Tax Administration issued Communications 030-E-2026-f and 031-E-2026-f on April 7, 2026, applying the OECD’s January 2025 and January 2026 Administrative Guidance on the Pillar Two GloBE rules to the Swiss domestic implementation. The Communications adopt the Inclusive Framework’s interpretations of the GloBE rules into Swiss administrative practice for the purposes of the Swiss Qualified Domestic Minimum Top-up Tax and the operation of the IIR and UTPR.

The January 2026 Administrative Guidance includes the Side-by-Side package agreed by the Inclusive Framework on January 5, 2026, which addresses the application of the GloBE rules to US-headquartered MNE groups and recognizes the US tax system as a Qualified Side-by-Side Regime in defined circumstances. Switzerland’s adoption of this guidance brings the Swiss Pillar Two regime into alignment with the latest international consensus and provides administrative certainty for MNE groups with Swiss operations.

OECD Inclusive Framework Agrees Side-by-Side Package on Pillar Two

Mon, 05 Jan 2026 00:00:00 +0000

The OECD/G20 Inclusive Framework on BEPS announced on January 5, 2026 that its members have reached agreement on a Side-by-Side package addressing the application of the Global Anti-Base Erosion (GloBE) rules to US-headquartered multinational groups. The package is designed to provide stability and certainty in the operation of Pillar Two by recognizing the US tax system as a Qualified Side-by-Side Regime in defined circumstances.

Under the agreement, US-headquartered MNE groups are exempt from the Income Inclusion Rule and the Undertaxed Profits Rule for fiscal years beginning on or after January 1, 2026, where the relevant conditions are satisfied. The package also includes material simplifications and greater alignment of substance-based tax incentives with qualified refundable tax credits. The Administrative Guidance is expected to be incorporated into the Commentary to the GloBE Model Rules in due course.

Transfer Pricing in the International Tax Architecture

Thu, 11 Dec 2025 00:00:00 +0000

Transfer pricing is one of several mechanisms in the international tax system for allocating multinational income across jurisdictions. It is the most analytically detailed of these mechanisms, but it is not the only one, and a transfer pricing position cannot be designed without reference to the others. This article surveys the broader architecture in which transfer pricing operates, identifies the principal interactions between transfer pricing and other international tax provisions, and illustrates one such interaction through a worked example. The discussion is global in framing, with US-specific provisions and OECD-aligned international rules treated together where each is most relevant.