Pillar 2 Side-by-Side Rules (2026)

Nadia Lodroman | Oracle EPM Consultant | Integrity in Every Insight.

12 January 2026

Listen to Tresora and Ledgeron's chatting about this blog post:

Why Oracle TRC & Narrative Reporting are Essential

The European Commission’s notice on January 12, 2026, officially endorsing the OECD’s Side-by-Side (SbS) Package, marks a significant milestone in the global minimum tax journey. While the package introduces much-needed simplifications—including the permanent Simplified ETR Safe Harbour (SESH) and the SbS Safe Harbour for U.S.-parented groups—the compliance burden has shifted rather than vanished.

As an Oracle EPM Consultant specialising in Tax Reporting and Narrative Reporting, I’ve seen how these "simplifications" can be deceptive. Here is why Oracle TRC and Narrative Reporting are more critical now than they were before the safe harbor release.

1. Safe Harbours are an Election, Not an Exemption
The most critical takeaway from the SbS Package is that safe harbors are not automatic. They are elections that must be proven and reported.
  • The Filing Requirement Remains: Even if a jurisdiction qualifies for the Simplified ETR Safe Harbour (SESH), the MNE Group is still required to fulfill its reporting obligations under the GloBE Rules.
  • Ongoing Reporting: You must still demonstrate that your "Simplified ETR" is at least 15% (or 17% for the extended transitional period) using audit-ready financial data.

2. Why Oracle TRC is Still Your Foundation
To elect a safe harbor, you first need to know you qualify.
  • Fresh Modelling: The SESH requires new modelling of jurisdictional outcomes to ensure you don’t accidentally fall into a top-up tax position. Oracle TRC allows for this rapid scenario testing .
  • Hybrid Compliance: Most global groups will operate in a "hybrid" state—some jurisdictions will be in safe harbor, while others will require full GloBE calculations. Oracle TRC handles this complexity seamlessly within a single auditable structure .

3. The "Last Mile": Narrative Reporting as the Essential Extension
While TRC crunches the numbers, Oracle Narrative Reporting is what gets you across the finish line.
  • Producing the Reports: The filing requirement means you still need to produce high-quality, presentation-ready compliance reports for tax authorities and stakeholders .
  • Combining Data and Commentary: Narrative Reporting allows you to pull live data from TRC and combine it with the qualitative explanations required for safe harbor elections and Pillar Two disclosures .
  • Efficiency: Instead of manual copy-pasting into Word or PDF, Narrative Reporting automates the production of the GloBE Information Return (GIR) or local jurisdictional filings, ensuring consistency across all documents .
Conclusion: Streamline, Don’t Just Simplify
The SbS Package is a welcome development, but it doesn’t eliminate the need for robust tax technology. My experience implementing Oracle Tax Reporting and Narrative Reporting has shown that the best results come from a unified approach: use TRC for the data and Narrative Reporting for the compliance delivery .

Is your reporting process ready for the 2026 Side-by-Side requirements? Let’s connect to discuss how to optimize your Oracle EPM environment for these new standards.
Beyond the Safe Harbour: Why Filing Obligations Demand Unified Tax and Narrative Reporting.

Turning financial complexity into operational clarity. Because in Finance, Integrity is Permanent.

General EPM Strategy FAQs

  • Why should a company use EPM Automate instead of custom scripting

    EPM Automate allows for robust, bi-directional data orchestration between Oracle EPM and source ERPs (like NetSuite or Fusion) using native capabilities. It is highly scalable, easier to maintain during Oracle's monthly updates, and avoids the fragility of heavy custom coding.

  • Can Oracle Cloud EPM integrate with multiple different ERPs simultaneously?

    Yes. Through strategic data pipeline architecture, Oracle EPM can ingest, consolidate, and even write-back finalized data to multiple disparate ERPs concurrently, acting as the single source of truth for the enterprise.

  • How does Oracle FCCS handle Minority Interest (NCI) and CTA?

    While standard FCCS provides out-of-the-box functionality, complex global enterprises often require advanced configuration to isolate and calculate Minority Interest (NCI) and Cumulative Translation Adjustments (CTA) accurately at the top consolidated hierarchy without relying on manual journals.

  • Can you bypass the out-of-the-box Goodwill calculation in Oracle FCCS?

    Yes. By utilizing advanced native configuration and custom consolidation rules, you can bypass standard Goodwill Input/Offset functionality to meet highly specific, non-standard acquisition accounting requirements.

  • How many daily transactions can Oracle ARCS process?

    Oracle ARCS is built for enterprise scale. With proper architecture in the Transaction Matching engine, ARCS can easily process and auto-match hundreds of thousands of daily banking transactions, representing billions of dollars in value.

  • What is the difference between Transaction Matching and Reconciliation Compliance in ARCS?

    Transaction Matching automates the high-volume, line-by-line matching of data (like daily bank feeds or ACH). Reconciliation Compliance is used to govern the period-end justification of broader balance sheet account balances.

  • Does Oracle TRC handle Country-by-Country Reporting (CbCR)?

    Yes. Oracle Tax Reporting Cloud (TRC) provides built-in frameworks to automate Country-by-Country Reporting, ensuring multinational organizations remain compliant with global BEPS (Base Erosion and Profit Shifting) regulations.

  • How does Oracle TRC integrate with FCCS?

    TRC and FCCS share the same platform architecture, allowing for seamless data flow. Finalized pre-tax consolidated data from FCCS feeds directly into TRC for tax provisioning, ensuring perfect alignment between the finance and tax departments.

Still have a question?

Contact me

All things Oracle EPM

A comparison infographic titled 'The ROI of Oracle TRC' showing the shift from manual Excel sheet.

Beyond the Spreadsheet

by Nadia Lodroman • 11 April 2026
Ditch the manual tax provision. Explore three ways Oracle Tax Reporting Cloud (TRC) provides immediate ROI through automated roll-forwards and state tax logic.
Screenshot of the Oracle TRC Tax Automation Rules screen showing the Apply All Accounts button

The Ghost in the Machine

by Nadia Lodroman • 10 April 2026
Discover the "Apply All Accounts" trick to recover out-of-the-box TAR rules and successfully add custom payment and refund logic in Oracle Tax Reporting Cloud.
An infographic illustrating advanced Tax Reporting features in Oracle EPM 26.04.

The Compliance Frontier (Tax Reporting)

by Nadia Lodroman • 1 April 2026
Master OECD Pillar Two compliance with Oracle EPM 26.04. Explore TRC updates, GloBE automation, currency translation, and valuation allowances.
Show More