Q2 2026 confirms a new direction in global taxation: the focus is no longer on creating new tax rules, but on aligning how those rules are monitored, administered, and enforced across jurisdictions.
Businesses no longer operate simply within different tax systems — they now operate within a global infrastructure of transparency, data exchange, and coordinated tax control.
Below are three key developments shaping this transition:
1) OECD Side-by-Side Regime: Partial Erosion of Pillar Two Universality
In 2026, the OECD formalised the Side-by-Side (SbS) approach as a permanent element of the Pillar Two framework. Its core idea is the recognition that the global minimum tax is not fully universal in its practical application.
This approach is закрепed through the OECD/G20 Inclusive Framework - Side-by-Side package (2026).
Practical implications include:
- certain multinational groups obtaining more stable safe harbour treatment;
- reduced exposure to IIR/UTPR application within specific structures;
- a more flexible interaction model between jurisdictions, particularly in relation to major economies outside the EU.
This marks the first clear indication that Pillar Two is evolving not as a rigid global standard, but as a modular framework with negotiated exceptions and differentiated application mechanisms.
2) DAC9 (EU): Centralisation of Group Tax Reporting
The European Union is moving into the next stage of tax integration through DAC9, which changes not the tax rates or substantive rules, but the administrative model itself.
The key concept is that multinational groups will submit a single consolidated Pillar Two return (TTIR), after which the information will be automatically distributed among EU tax authorities, significantly reducing duplicative local filings.
In practice, this creates the first operational element of a unified EU tax gateway for corporate taxation.
3)OECD GloBE Toolkit 2026: Standardisation of Tax Audits and Enforcement
The 2026 OECD GloBE updates shift the focus from tax calculation methodology toward the harmonisation of tax audits and enforcement procedures.
The new framework introduces:
- a standardised GloBE Information Return (GIR);
- unified risk assessment models for top-up tax exposure;
- automated cross-border data exchange mechanisms for audit purposes.
As a result, tax authorities across jurisdictions are beginning to operate under increasingly aligned enforcement logic - not only in theory, but also in day-to-day audit practice and operational control.
The global tax landscape is entering a new phase where competitive advantage is determined not only by tax structuring, but by the ability to operate transparently within interconnected compliance systems.
The central trend of Q2 2026 is therefore clear: the world is moving from harmonisation of tax rules toward harmonisation of tax enforcement.
✍🏻 Daryna Khalatian, Middle Consulting Department Manager
