OECD safe harbors: Targeted relief, but complexity remains a reality (13:32)

Pat Brown, Stewart Brant, Steve Kohart, Giorgia Maffini
Wednesday, January 21, 2026

The OECD’s Side-by-Side Package offered the prospect of simplification, but complexity and real obligations remain. Here’s what you need to know about how the five safe harbors work and why tax teams should be paying attention now as they plan for upcoming compliance cycles.

IN THIS EPISODE
Pat Brown, PwC’s National Tax Office Co-Leader
Stewart Brant, Managing Director, PwC’s Global Tax Policy Services Practice
Steve Kohart, Principal, PwC’s International Tax Services Practice
Giorgia Maffini, Special Advisor on Tax Policy and Transfer Pricing, PwC UK

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