OECD Pillar Two: Tax implications for US multinationals

The OECD’s January 2026 Administrative Guidance on Pillar Two introduces new safe harbor provisions that could significantly affect how US multinationals are taxed globally. This episode breaks down the key provisions and their accounting and financial reporting implications. In this episode, we discuss: 1:13 – Background on Pillar Two and core concepts 6:57 – Overview of the OECD Administrative Guidance 17:10 – Criteria for the Side-by-Side Safe Harbor 21:46 – Ultimate Parent Entity Safe Harbor overview 25:25 – Key accounting and financial reporting considerations 33:21 – Extension of the Country-by-Country Safe Harbor 35:15 – Final reminders and key takeaways For more information on accounting for Pillar Two, read our In depths, OECD Pillar Two: Time to act on the global minimum tax and Accounting for Pillar Two: Frequently asked questions . Also, check out our Income taxes guide for additional background on existing guidance. Be sure to follow this podcast on your favorite podcast app and

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OECD Pillar Two: Tax implications for US multinationals is an episode from PwC's accounting podcast by PwC.

This episode is 44:50 long.

This episode was published on Apr 14, 2026.

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