| Date | 27 - 29 October 2025 |
| Venue | To be confirmed |
| Location | Bangkok, Thailand |
| Early bird discount | Early Bird 10% until 20 September 2025 |
The course will explore how the rules are expected to apply, as well as some of the more surprising outcomes that may arise from the application of these rules in areas such as:
scope of application of IIR, UTPR and QDMTT and the order of application, application of Pillar Two to international tax planning structures such as holding, financing, IP and supply chain structures, including examples of country implementation of Pillar Two.
It also aims to simplify complying with Pillar Two that involves determining and electing to apply the safe harbours, GloBE information returns and compliance obligations and dealing with special in-scope entities and out-of-scope entities.
The masterclass also covers QDMTT and changes to tax competition and incentive regimes, Pillar Two considerations in M&A transactions and intragroup transfers and potential areas of disputes and disputes management options
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, the Netherlands |
Other instructors to be confirmed
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.