Fundamentals of the GloBe Rules - Pillar Two

Scope and top-up tax

• Introduction, consolidation under IFRS and different GAAPs
• Scope; test of annual revenue in the consolidated financial statements; excluded entities and the extent of the exclusion
• Effective tax rate calculation; jurisdictional blending; adjusted covered taxes and net GloBE Income; substance-based income exclusion; payroll and tangible assets carve-out; excess profit and top-up tax calculation and the allocation of top-up taxes to constituent entities

The charging mechanisms

• The charging system of the GloBE Rules; IIR and UTPR; the paying entities: ultimate parent entity, intermediate parent entity and partially-owned parent entity
• The hierarchy of IIR paying entities; the role of controlling interest and allocable share; offset mechanism
• The optional mechanisms of the UTPR; denial of deduction and equivalent adjustment; the exclusion mechanism and the deduction mechanism and the allocation of the total UTPR top-up tax amount

GloBE Income or Loss

• From consolidation to GloBE Income or Loss; other comprehensive income (OCI); and the adjustments of financial accounting net income or loss to arrive at GloBE Income or Loss
• Flow-through entities: tax transparent entities and reverse hybrid entities; the allocation of income or loss from a flow-through entity
• The refundable tax credit qualified or non-qualified; the relevance of the refundable tax credit for the effective tax rate

Adjusted covered taxes

• From covered taxes to adjusted covered taxes; withholding taxes and the total deferred tax adjustment amount and other adjustments
• The allocation of taxes in case of permanent establishments; tax transparent entities; controlled foreign company tax regimes and hybrid entities
• Deferred tax expense and the calculation of the total deferred tax adjustment amount; the deferred tax asset recast at the minimum rate; the recapture of a deferred tax liability and the recapture exception accrual

Qualified domestic minimum top-up tax (QDMTT)

• The difference between a qualified and non-qualified domestic minimum top-up tax and the impact of the substance-based income exclusion
• The requirements for a qualified domestic minimum top-up tax (QDMTT): consistency in design and outcomes; payment of the QDMTT; charging more than the GloBE Rules
• QDMTT and other taxes: taxation of a permanent establishment and interaction with controlled foreign company tax regimes

After completing this course, participants will be able to:

• Calculate the top-up tax under Pillar Two
• Identify which charging mechanism will apply
• Calculate the top-up tax under the QDMTT
• Determine the GloBE Income or Loss
• Determine the adjusted covered taxes

• Hans Pijl, IBFD, The Netherlands
• Carlos Gutiérrez Puente, IBFD, The Netherlands

This course is suitable for practitioners in government such as tax inspectors and newly hired employees who need to build up their knowledge of Pillar Two and government officials from developing countries who regularly encounter issues related to Pillar Two. 

It is equally suitable for the tax advisory industry and large MNE groups, to give their people a good starting point in the complexities of Pillar Two; not to forget anyone who simply desires a foundational understanding of the Pillar One and Two principles.

Although this course is not explicitly tailored for the CIOT Pillar Two Award, it serves as a valuable resource for individuals preparing for this qualification. For details about this credential, please visit the CIOT website.

Participation in the course does not require prior experience or knowledge of Pillar One and Two.

No advance preparation is necessary. All required study material is provided within the online training.

Access to the online course is granted for a period of 2 months, from the date of ordering or the indicated start date.

Mandatory course activities: 6 hours

All mandatory course activities can be completed within the access period by dedicating approx. 1 hour of study per week. Please note that study materials included in the course or certificate programme will be accessible for the duration of the access period only. Non-mandatory supplementary material is also provided in this course.

We recommend you check with your respective accrediting organizations to determine the eligibility of CPE credits.

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 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 is: 6

See our FAQ section for more information. Regarding administrative policies such as complaint, cancellation or refund, please refer to our Terms and Conditions or contact us at info@ibfd.org. 

Field of study: Taxes

Delivery format: Online - QAS Self Study

Course level: Introductory (basic)

Please note that the content of this online course is subject to change based on updates in industry standards, regulatory requirements, and other developments. We strive to provide the most accurate and current information; however, we recommend verifying any critical details independently.

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.