The OECD Model Rules and EU Pillar Two Directive: from ETR to UTPR (Europe – Americas session)

This live online webcast edition is designed in a pragmatic manner to discuss the general architecture of Pillar Two, one of the most debated and popular topics currently. More than 135 jurisdictions have agreed to the Two-Pillar-Solution.


The main part of this webcast is about the architecture of the Model Rules/Directive, i.e. their calculatory and charging provisions. After this first class you’ll be able to make the required calculations and arrive at the IIR and UTPR payable by which Entity.

We systematically lead you through the calculatory and charging rules, accompanied by many numerical examples while clarifying the complex and well-designed system. This engaging live webcast is full of examples, deeply founded in the texts of Model Rules and Directive.

Topics Covered 

Our course curriculum differs from the previous webinars offered online on this subject since we steer away from the history and aim of Pillar Two and its considerations in general. We rather focus on answering technical questions, such as the following: 

  • How does Pillar Two work as its calculatory and charging architecture is concerned?
  • Where do you start with a focus on this architecture? 
  • Where in these rules do you take the stand-alone Constituent Entity and where do you take Constituent Entities on a jurisdictional basis together?
  • Which Entity is to pay the IIR, and how do we prevent economic double taxation there?
  • How do we allocate the IIR and UTPR?
  • Why do the Model Rules not prescribe how the jurisdictional UTPR is to be allocated to the Entities exactly?
  • Could we qualify the system of the Model Rules as less efficient than the Directive at the point of applying the UTPR? 

About the course

After following this webcast edition, participants will be able to: 

  • List the calculatory and charging features of Pillar 2
  • Identify in-scope entities, and calculate the jurisdictional Effective Tax Rate (ETR) and top-up tax under the Pillar Two rules
  • Determine the top-up tax for the Constituent Entities
  • Appreciate the charging mechanism of IIR and UTPR

Who should participate

The online webcast is suitable to advisers in advisory firms, government officials, tax inspectors, lawyers (both in-house and in law firms), academics, and anyone who desires to get a practical understanding of the calculatory and charging aspects of the Model Rules and the EU directive. This webcast is also meant for anybody who is interested in the working of Pillar Two.

Delivery method

Instructor led, online, 3.5 hour masterclass with three short breaks.

* The webcast will be conducted in a live online environment. The registered participants will receive the login details a few days before the start of the class.

Field of study

International taxation, Pillar Two, GloBE rules, Inclusive Framework/OECD Model Rules, Draft Pillar Two Directive COM(2021) 823 final