OECD Says ‘Side-by-Side’ Deal Will be Applied Jan. 1 by Nations

Countries have committed to applying a system that would exempt US companies from two key rules in the global minimum tax framework, effective as of Jan. 1, 2026, a senior OECD official said Thursday.

Some countries will need to legislate guidance applying the so-called “side-by-side” system, said Achim Pross, deputy director of the OECD’s Center for Tax Policy and Administration. To the extent that countries are required to apply these new rules, it may take a jurisdiction up to a year to incorporate them into local law.

“They have committed to those dates, so there is a review process ...