OECD's P2 Side By Side Package : It's Not You, It's Your UTPR

The US and Pillar Two were never going to be a perfect match. After a threatened tax war, a last-minute G7 deal, and a "revenge tax" that got pulled days before passage, the two systems have agreed to coexist—awkwardly. On January 5, 2026, the OECD made it official: US-parented multinationals can elect out of IIR and UTPR starting this year. But don't cancel your compliance subscriptions just yet. QDMTTs still apply, 2024–2025 filings are still due, and the GIR still needs to be filed. In this episode, we break down what Side-by-Side actually means for US MNEs, why transfer pricing is now your primary Pillar Two battleground, and what happens if you lose an audit in a QDMTT jurisdiction. The honeymoon is over. The paperwork isn't.