OECD Working on Continuity Guidance for ‘Side-by-Side’ Deal (1)

March 19, 2026, 3:40 PM UTCUpdated: March 19, 2026, 7:19 PM UTC

Countries at the OECD are working on administrative guidance to clarify how a new agreement to carve out US companies from the global minimum tax will work, an official from the Irish Finance Ministry said.

Working Party 11, a group of jurisdictions’ tax technical experts, is developing guidance on the continuity of the so-called “side-by-side” package and “what happens when people fall in and out of the side-by-side system,” Gary Hynds, the ministry’s head of international tax, said Thursday at a Boston conference sponsored by the US branch of the International Fiscal Association.

Countries will need the guidance to codify ...

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