Pillar Two Analysis:

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Simplified ETR Safe Harbour

Sample Excel File for the Simplified ETR Safe Harbour

On January 5, 2026, the OECD Released Guidance on amendments to the Pillar 2 rules for the Side-by-Side Tax Package. This includes a new Simplified ETR Safe Harbour from December 31, 2026 (December 31, 2025 in certain cases). We provide an excel overview for the key elements of the Safe Harbour calculation.

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Turkey Issues a Communique for Detailed Pillar 2 Implementation

On December 26, 2025, Turkey published the Communique on the Minimum Tax Law. Whilst Turkey has enacted its Minimum Tax Law, a lot of the detailed application of the GloBE rules was left to a further Regulation. This Communique therefore provides for the detailed rules for the implementation of the GloBE rules in Turkey.

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