Important Notice
The Side-by-Side Package for Pillar Two, released by the OECD in January 2026, has reshaped the global minimum tax regime. The aim of the package is to make the coexistence of different minimum tax systems more practical by introducing additional safe harbours, structural simplifications, and clarifications. In particular, the package includes the Side-by-Side System, the Simplified Effective Tax Rate (ETR) Safe Harbour, an extension of the Transitional Country-by-Country Reporting (CbCR) Safe Harbour, and the Substance-based Tax Incentive Safe Harbour.
In this webinar, the speaker will highlight the key features of the Side-by-Side Package and share her insights on the potential implications for multinational enterprises, the impact on existing tax incentives in Hong Kong, and the applicability of the newly introduced safe harbour rules to multinational groups operating in Hong Kong.
