Current Affairs · International Agreements & Tax Policy

In July 2025, an arrangement was introduced between G7 nations and subsequently via OECD administrative guidance concerning a 'side-by-side' (SbS) taxation model. Which of the following statements regarding this agreement is/are correct? 1. The arrangement essentially creates a framework to exempt qualified U.S. multinational groups from certain provisions (like IIR and UTPR) of the 15% global minimum tax under the OECD Pillar Two framework. 2. U.S. companies will now be subject to a strict cumulative tax in both the specific foreign jurisdictions where they operate and in the United States based on a dual-allocation model. 3. This agreement marks a significant deviation from the original rigid implementation timelines of the OECD framework negotiated in 2021, incorporating new safe harbors.