BEPS Inclusive Framework Agrees on Side-by-Side Arrangement for Pillar 2 Including Safe Harbors to Exempt MNE Groups Headquartered in Eligible Jurisdictions

The OECD has announced that the members of the BEPS Inclusive Framework have agreed on the key elements of a Side-by-Side arrangement that includes, among other things, two safe harbors that apply to MNE Groups headquartered in jurisdictions recognized by the Inclusive Framework as having an eligible tax regime. A Side-by-Side (SbS) Safe Harbor exempts such MNE Groups from the Income Inclusion Rule (IIR) and Undertaxed Profits Rule (UTPR) in other jurisdictions, whereas an Ultimate Parent E…