Masterclass - Pillar Two Implementation: Impact Assessment, Compliance and Planning Beyond Global Minimum Taxes
OECD Pillar Two proposals imposing 15% minimum taxes on profits of multinational groups (i.e. global revenue of EUR 750 million) are being widely implemented. These rules came into effect in many countries, including some in the Middle East and North Africa. This state of flux is likely to raise many practical questions for multinational groups facing potential top-up taxes, as well as for countries introducing the top-up taxes.
This three-day masterclass explores the practical impact of Pillar Two top-up taxes that may be imposed under the QDMTT, IIR and UTPR. The course will explore how the rules are expected to apply, as well as some of the more surprising outcomes that may arise from the application of these rules in the following areas:
- scope of application of IIR, UTPR and QDMTT and the order of application
- application of Pillar Two to international tax planning structures – e.g. holding, financing, IP and supply chain structures
- examples of country implementation of Pillar Two
- complying with Pillar Two
- determining and electing to apply the safe harbours
- GloBE information returns and compliance obligations
- dealing with special in-scope entities and out-of-scope entities
- QDMTT and changes to tax competition and incentive regimes
- Pillar Two considerations in M&A transactions and intragroup transfers
- potential areas of dispute and dispute management options