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News & Insights

Side-by-Side Agreement Is Crucial Step Forward in International Tax Framework Negotiations

January 5, 2026


WASHINGTON D.C. – National Foreign Trade Council (NFTC) Vice President for International Tax Policy Anne Gordon today issued the following statement:

“Today’s announcement that the OECD Inclusive Framework created a safe harbor for robust national tax systems like that of the United States is a crucial step forward in the long path toward securing a more certain international tax framework. This move recognizes that tax systems which accomplish the goals of BEPS are on par with the Pillar Two global minimum tax and should therefore coexist with the international framework.

“Additionally, ensuring an appropriate treatment for non-refundable credits and other tax incentives is a much-needed development, which has long been a priority of the U.S. business community by allowing countries to determine the best model for incentivizing real economic investment without disadvantaging American companies. 

“We also welcome the temporary extension of the Transitional CbCR Safe Harbor and creation of the Ultimate Parent Entity Safe Harbor, which will provide a more seamless transition for companies to the new guidance, including the Simplified Effective Tax Rate Safe Harbor.

“Thank you to the administration for its commitment to these negotiations and for ensuring that American companies can compete on a level playing field and are not burdened by superfluous or duplicative requirements, and to Congress for their dedication to the success of American companies globally.

“NFTC looks forward to comprehensively reviewing the guidance from the OECD and will continue to participate in this process to minimize any unintended consequences resulting from the integration of the two systems.”

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About the NFTC

The National Foreign Trade Council (NFTC) is the premier business association advancing trade, tax, national security and supply chain policies that support access to the global marketplace. Founded in 1914, NFTC promotes an open, rules-based global economy on behalf of a diverse membership of U.S.-based businesses, who account for over $6 trillion in revenue and employ nearly 6 million people in the United States.

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