OECD meeting in Paris: What the Pillar 2 and AI declarations mean for businesses

What you can expect from this article

The plenary meeting of the OECD/G20 Inclusive Framework on BEPS took place in Paris from 28 to 30 October 2026. Among other things, the participating countries discussed simpler rules for the global minimum tax (Pillar 2) and the potential applications of AI in tax administration. But what do the statements from the meeting mean for businesses?

Check now: Are you affected by the ‘side-by-side’ issue?

With the so-called ‘side-by-side’ package, the OECD aims to establish a framework between Pillar 2 and national minimum tax systems, in particular the US GILTI and CAMT schemes. Under this package, companies headquartered in jurisdictions with a recognised, equivalent minimum tax system are to be fully protected from foreign catch-up tax assessments. In addition, the temporary CbCR safe harbour has been extended by one year, and a permanent simplification of the calculation of the effective tax rate (ETR) has been discussed.

For companies, this means checking whether the ‘side-by-side’ approach and, where applicable, the simplifications actually apply to their group of companies, the country in question and the financial year. It is also necessary to clarify which tax returns and declarations are still required. The tax department, the accounts department and the local subsidiaries should work together to determine who is responsible for providing and verifying which information.

Can the CbCR figures provided be explained?

With Country-by-Country Reporting (CbCR), more than 120 countries and tax jurisdictions have introduced country-by-country reports for corporate groups. Tax authorities use these reports to make an initial assessment of where tax risks might lie in transactions between group companies. However, even when the data is correct, noticeable discrepancies may appear in a report.

Our recommendation: As a first step, companies should check whether the information relating to their consolidated figures is consistent with the records of internal transactions. Furthermore, companies should be able to provide a clear explanation for every figure. This is the only way to justify any noticeable discrepancies to the authorities. After all, a discrepancy is not automatically an error.

What can businesses expect when tax authorities turn to AI?

The OECD meeting, held as part of the „Tax Administration 3.0“ (TA3.0) project, also addressed the use of artificial intelligence (AI) in tax administration. This is driven by the expected volume of data resulting from future submissions, such as Pillar 2 reports. AI is to be used to automatically identify patterns of cross-border tax evasion and abusive tax planning.

For businesses, this means that in future it will be virtually impossible to get away with inaccuracies or tricks. You should therefore keep a very precise record of where your tax data comes from, how the figures were calculated and who checked them. Document any discrepancies and the reasons for them. This will enable you to provide the correct answer to any queries from the tax authorities. Don’t wait until the tax authorities are sifting through your reports using the full power of AI – by then, it will be too late.

If you have any further questions, please do not hesitate to get in touch. We look forward to hearing from you.