OECD/ G20 Inclusive Framework on BEPS Pillar Two proposals concerning the Global Minimum Tax (GMT) imposing 15% minimum taxes on the profits of multinational groups with global revenue of at least EUR 750 million are being implemented by countries. These rules came into effect in many countries, including some in the Asia-Pacific region, from 2024. This state of flux will likely raise many practical questions for multinational groups facing potential top-up taxes, as well as for countries introducing top-up taxes.

This three-day Masterclass explores the practical impact of Pillar Two GMT 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.

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

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
  • mergers and acquisition and intragroup 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 the design of tax incentives, mergers and acquisitions and cross-border tax disputes. 

Instructors 

• Shee Boon Law, IBFD, Independent Tax Consultant
• Carlos Gutiérrez Puente, IBFD, Senior Principal Associate

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 prior to joining this course. 

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: 18

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

Final location in Bangkok to be confirmed

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.