The OECD released the administrative guidance that included the long‑awaited Side‑by‑Side agreement on 5 January 2026.

Quick Scoop

  • The guidance is part of the Pillar Two Administrative Guidance package and is often referred to as the “Side‑by‑Side package” or “Side‑by‑Side system.”
  • Several professional summaries (PwC, KPMG, law firms, and tax advisors) all describe the OECD’s publication as having been released on 5 January 2026, confirming the date.

In one line

On 5 January 2026, the OECD published Administrative Guidance under Pillar Two that formally set out the Side‑by‑Side agreement and related safe harbors.

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