OECD Pillar Two proposals are being implemented by countries from 2024 in a race to protect their tax revenue from other countries imposing top-up taxes on profits of in-scope multinational groups operating in their countries. This state of flux will likely raise many practical questions for multinational groups facing potential top-up taxes, as well as countries introducing 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 their application in the following areas:

• Scope of application of IIR, UTPR and QDMTT and the order of application
• QDMTT and changes to tax competition and incentive regimes
• 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
• Pillar Two considerations in M&A transactions and intra-group transfers 
• Potential areas of disputes and dispute management options

The course will demystify the complex Pillar Two rules using examples, case studies and group discussions based on real-life examples.

Topics Covered

• Scope of Pillar Two rules
• Impact assessment under Pillar Two
  • Application of IIR, QDMTT and UTPR
  • Potential impact on international tax planning structures
• Global developments on Pillar Two implementation
• Pillar Two compliance
  • Application of safe harbours and simplified ETR
  • GloBE information returns and compliance obligations
• Post-Pillar Two international tax landscape:
  • Tax competition and tax incentives/investment funds
  • Mergers and acquisition and intra-group transfers
  • Disputes and disputes management

Learning Objectives

After this masterclass, the participants will be able to: 

• Assess the impact of Pillar Two implementation on common international tax planning structures.
• Identify the compliance obligations under Pillar Two. 
• Develop strategies to deal with changes in the international tax landscape including designs of tax incentives, mergers and acquisitions and cross-border tax disputes.

Instructors 

Field of study

Taxes

Who should attend

The course is suitable for government staff, tax advisers, lawyers, accountants, in-house tax directors, controllers and finance staff.

Course Level and Prerequisites

This is an intermediate-level course. Participants taking this course will be expected to have an understanding of the basic concepts of the GloBE rules. Those who do not meet this requirement are recommended to follow IBFD’s online Fundamentals on GloBE Rules – Pillar Two.

Continuing Professional Education (CPE)

International Bureau of Fiscal Documentation (IBFD) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have the final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National. Registry of CPE Sponsors through its website: www.nasbaregistry.org. Recommended NASBA CPE credits for this course are: 21

Please consult the FAQ for more information. Regarding administrative policies such as complaints, cancellations and refunds, please refer to our Terms and Conditions or contact info@ibfd.org.

Venue

To be decided

Disclaimer

• IBFD reserves the right to cancel this Masterclass up to 1 month before the commencement date.
• The programme and line-up of speakers are subject to change.
• In the unfortunate event of the masterclass being cancelled, registered participants will receive a credit note by email at the email address provided and a full refund of the masterclass registration fee thereafter. In light of this, participants are kindly advised to make refundable travel and accommodation arrangements. Participants act at their own risk when booking non-refundable travel and accommodation arrangements. IBFD is not responsible for any loss incurred by participants who book non-refundable travel and accommodation arrangements.
• All bookings related to travel and accommodation, as well as local transportation, visas, vaccinations and travel insurance are at the participant’s own cost.