Fundamentals of the Global Minimum Tax
As more than 50 jurisdictions move forward with the implementation of the OECD/G20 Inclusive Framework’s Pillar Two Global Minimum Tax (GMT), the international tax landscape is undergoing one of the most significant transformations in decades. Countries are introducing the GloBE rules and the Qualified Domestic Minimum Top-up Tax (QDMTT), confronting complex policy design choices while navigating continuous interpretative developments. At the same time, multinational enterprises and tax administrations must apply highly technical, interconnected, and fast‑evolving rules—further shaped by the latest Administrative Guidance and recent political milestones, such as the Side‑by‑Side Package agreed by the United States and the G7.
This three‑day fundamentals course is designed to give participants a clear, structured and practice‑oriented introduction to the GMT framework. It is ideal for professionals new to Pillar Two, as well as those looking to consolidate their foundational knowledge before advancing to higher‑level technical analysis. The programme blends conceptual explanations, walkthroughs of rule mechanics, practical examples, and interactive discussions to build confidence and understanding across all core elements of the GloBE rules.
Claim your 10% early‑bird discount before 10 April 2026.
- Introduction to the OECD/G20 Pillar Two framework, including Model Rules, Commentary, and Administrative Guidance.
- Jurisdictional Effective Tax Rate (ETR) determination and the mechanics of the top‑up tax.
- Overview of the charging rules: Income Inclusion Rule (IIR), and Undertaxed Profits Rule (UTPR), and interaction with QDMTT.
- Scope of the GloBE rules, including in‑scope vs out‑of‑scope MNEs, excluded entities, and transitional rules.
- Application of Safe Harbours, including CbCR transitional safe harbour and permanent ETR safe harbours.
- Calculation of GloBE Income, Adjusted Covered Taxes, and treatment of deferred tax.
- Special entity considerations: PEs, transparent and hybrid entities, reverse hybrids, JVs, investment entities, and MOCEs.
- QDMTT in practice, including alignment with GloBE rules, qualified status, and interaction with domestic tax incentives.
- Compliance and administration: GloBE Information Return (GIR), notification and filing requirements, elections, and compliance timelines.
- Latest global developments, including the IF peer review process and the Side‑by‑Side Package between the US and G7.
After this course, participants will be able to:
- Explain the core structure and policy rationale of the OECD/G20 Pillar Two framework, including how the GloBE rules aim to address base erosion and profit shifting.
- Identify which multinational enterprise groups fall within the scope of the GloBE rules, including excluded entities and the role of transitional and permanent safe harbours.
- Describe the mechanics of the jurisdictional Effective Tax Rate (ETR) calculation, including the determination of GloBE Income and Adjusted Covered Taxes.
- Understand how top‑up tax is computed and distinguish between the application of the QDMTT, Income Inclusion Rule (IIR), and Undertaxed Profits Rule (UTPR).
- Apply foundational concepts to practical examples, including simple structures involving, for example, permanent establishments.
- Assess the relevance and impact of safe harbours, including the transitional CbCR safe harbour and permanent ETR safe harbours, in reducing compliance obligations.
- Explain the significance of QDMTT and its interaction with domestic tax incentives
- Explain the relevance of the Side‑by‑Side Arrangement.
- Navigate the basic compliance framework of the GMT, including filing, notification, registration, and the GloBE Information Return (GIR).
- Recognise key administrative challenges tax authorities and MNEs may face during early implementation, including data requirements and coordination across jurisdictions.
- Monitor and interpret ongoing international developments, such as new Administrative Guidance or peer review outcomes, and understand how these may influence the evolving application of the rules.
- Carlos Gutiérrez P., IBFD, the Netherlands
- Shee Boon Law, IBFD consultant, the Netherlands
- Min Shi, IBFD, the Netherlands
The course is suitable for:
Government officials, tax advisers, lawyers, accountants, in‑house tax directors, controllers, finance staff, and corporate tax professionals.
IBFD Head Office - Amsterdam
This is an introductory/intermediate‑level course. Participants taking this course will be expected to have a good understanding of the basic concepts of international taxation including BEPS.
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.
In accordance with the standards of the National Registry of CPE Sponsors, CPE credits have been granted based on a 50-minute hour. (National Registry of CPE Sponsors ID Number: 107989)
Number of CPE credits: 22.5
See our FAQ section for more information. Regarding administrative policies such as complaint, cancellation or refund, please refer to our Terms and Conditions or please contact us via email.
Field of Study - Taxes
IBFD reserves the right to cancel this course 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 course being cancelled, registered participants will receive a credit note by email at the email address provided and a full refund of the course 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. Registered participants will receive a list of hotels that offer corporate rates.
Group Participation
If you are an enterprise and would like to register a group of more than 5 participants from your company, please email us at info@ibfd.org for more details.
