OECD/G20 Inclusive Framework on BEPS Pillar Two proposals concerning the Global Minimum Tax (GMT) are being implemented by countries from January 2024 in a race to protect their tax revenue from other countries imposing top-up taxes on profits of in-scope multinational groups operating in their countries.  This state of flux will likely raise many practical questions for multinational groups facing potential top-up taxes, as well as countries introducing top-up taxes.

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

Topics Covered

• Impact assessment of GMT
  • Scope of application of IIR, UTPR and QDMTT and the order of application
  • Examples in the application of GloBE Rules
  • Application to special entities under the GloBE Rules
  • Implementation of QDMTT: mandatory and optional variations
• GMT compliance obligations
  • Dealing with compliance obligations of an in-scope MNE Group
  • Examples of country implementation of GMT and (un)expected compliance obligations
  • Application of Transitional Safe Harbours and Permanent Safe Harbours
  • GloBE information returns and compliance obligation
  • Application of GMT to international tax planning structures – e.g. holding, financing, IP and supply chain structures
• Post-GMT international tax landscape
  • Tax competition, QRTCs and design of tax incentives
  • Pillar Two considerations in M&A transactions
  • Potential areas of disputes and dispute resolution mechanisms

Learning Objectives

After this masterclass, the participants will be able to:

• Assess the impact of Pillar 2 implementation on common international tax planning structures.
• Identify the compliance obligations under Pillar 2.
• Develop strategies to deal with changes in international tax landscape including designs of tax incentives, mergers and acquisitions and cross-border tax disputes.

Instructors 

Shee Boon Law, IBFD, Independent Tax Consultant

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.

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.

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: 18

In accordance with the standards of the IAB-IEC, CPE credits have been granted based on a full hour. (IAB-IEC recognition nr. B0181/2010-09)
Number of CPE credits: 17

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.

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. Registered participants will receive a list of hotels that offer corporate rates.