Cross border disputes and dispute resolution under OECD Pillar 1 and Pillar 2

The OECD’s two-pillar solutions are expected to reconfigure international tax rules and will likely set the tone for cross-border international tax disputes in the future. These rules are complex and create significant compliance challenges. Disputes with individual tax authorities and between tax authorities of different countries, which are bound to happen, need to be resolved, and swiftly.

What are some of the areas where disputes may arise under Pillar One and Pillar Two, and how should multinational groups anticipate them? What are the tax certainty mechanisms available under the OECD rules for Pillar One and Pillar Two for multinational groups? Where are the gaps and the stress points in these proposals for tax certainty mechanisms that multinational groups should anticipate? 

Topics Covered

Block 1: OECD Pillar One Implementation

  • Potential areas of disputes under Pillar One
  • Mechanisms for preventing and resolving disputes under Pillar One

Block 2: OECD Pillar Two Implementation

  • Potential areas of disputes under Pillar Two
  • Mechanisms for preventing and resolving disputes under Pillar Two

Block 3: Impact on Multinational Groups

  • Assessing the anticipated impact on multinational groups

Learning Objectives

After this webinar, the participants will be able to: 

  • Identify the areas in OECD Pillar One and Pillar Two that are most likely to be associated with cross-border disputes
  • Define the options that are available under OECD Pillar One and Pillar Two proposals to resolve the potential disputes
  • Compare the OECD Pillar One and Pillar Two tax certainty approaches with conventional approaches in terms of the likelihood of disputes and methods for dispute resolution
  • Assess the likely impact of these disputes and usefulness of the proposed dispute resolution mechanisms for multinational groups


  • Ralf Thelosen, CITCO, the Netherlands 
  • Sorina van Kommer, Head of Knowledge, DLA Piper
  • Shee Boon Law, Consultant, the Netherlands
  • Diana Calderon Manrique (Facilitator)

Field of study


Who should participate

  • In-house tax professionals and advisers looking to understand the impact of OECD Pillar One and Pillar Two rules on the international tax arrangements of multinational groups
  • Legal professionals assessing the compliance risks of OECD Pillar One and Pillar Two rules, how to comply with the associated rules and manage the potential controversy risks associated with these rules
  • Government officials engaging in policy decisions related to OECD Pillar One and Pillar Two implementation, as well as those responsible for monitoring and controlling the compliance activities of multinational groups

Course level and prerequisites

This is an intermediate-level webinar. Participants in this webinar are expected to have at least 3 to 5 years of experience in international tax and be familiar with the key concepts of international tax law.

Advance preparation

No advance preparation is needed. Participants are expected to be familiar with the key concepts of international tax law.

Interactive webinar – “Group Internet Based” (live webinar only)

During live webinars, it is possible to interact with the presenters via a chat message function. Please note that questions are answered based on relevance, order of receipt and available time. Additionally, participants in the live webinar are invited to answer poll questions. Participants will also have access to the on-demand version for a further 12 months from the live date.

Date of live broadcast: 22 August 2023

On-demand webinar

On-demand webinars are intended for individual self-study only. Unlike live webinars, they are not open to interactive participation nor do they offer the assistance of a real-time instructor. Access to on-demand webinars is granted for a period of 12 months.

Continuing Professional Education

Many accrediting organizations will grant continuing professional education (CPE) credit(s) for an IBFD audio-visual broadcast. It is advisable, however, that you check with your accrediting body as to whether this applies only to live webinars or to on-demand webinars as well. International Bureau of Fiscal Documentation (IBFD) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of CPE 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: NASBA CPE credit – 1 (only applicable to live webinar).

Webinar registration details

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