OECD Pillar Two: Tax implications for US multinationals

PwC's accounting podcast · Apr 14, 2026 · 44m · transcript

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…