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 Country-by-Country Safe Harbor
35:15 – Final reminders and key takeaways

For more information on accounting for Pillar Two, read our In depths, OECD Pillar Two: Time to act on the global minimum tax and Accounting for Pillar Two: Frequently asked questions. Also, check out our Income taxes guide for additional background on existing guidance.

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About our guests

Pat Brown is PwC’s National Tax Office Co-Leader. Prior to joining PwC, he spent 16 years in the private sector, including as the director of tax policy for a Fortune 50 company. Pat has also served in the US Treasury’s Office of Tax Policy as an attorney-advisor and as Associate International Tax Counsel.

Jennifer Spang is PwC’s National Office income tax accounting leader, specializing in tax accounting under US GAAP and IFRS. She has over 30 years of experience helping companies in a variety of industries navigate complex tax accounting matters.

About our guest host

Kyle Moffatt is PwC’s Professional Practice leader, leading a team responsible for working with standard setters and regulators as well as delivering brand-defining thought leadership and educational materials. He also consults with engagement teams and audit clients on SEC reporting matters. Before PwC, Kyle spent almost 20 years with the SEC, most recently as Chief Accountant and Disclosure Program Director in the Division of Corporation Finance.

Transcripts available upon request for individuals who may need a disability-related accommodation. Please send requests to us_podcast@pwc.com

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OECD Pillar Two: Tax implications for US multinationals