Pillar Two: Advanced Technical Aspects of GloBE Rules

This masterclass is to be scheduled until further notice. In the meantime, check out other upcoming Masterclasses here.  

If you wish to have training on this topic customised to your organisation's needs, learn more about our Tailored Tax Training offerings or contact us directly at tailoredcourses@ibfd.org.

This 3-day advanced Masterclass in Amsterdam helps you gain a deep understanding of the GloBE Rules in their complicated interaction and how to apply them in practice.



The GloBE Rules/Pillar Two will keep the tax community more than unusually busy for the next years: 2024 is the first year in which the rules will apply, e.g. in the European Union States, Japan, Norway, Canada and others. It will also be the year of further refinements of the rules, and more sets of administrative guidance may be expected. Without doubt, the coming years will also show the expansion of GloBE and QDMTT rules to other jurisdictions. 2026 will have its own dynamics, as the year in which the first GloBE Information Returns will have to be filed. Lastly, starting in 2027, the first disputes may come to the table. 

This 3-day masterclass explores advanced issues related to the GloBE Rules and the adjacent areas of STTR, interaction of the GloBE Rules with the existing legal framework, safe harbours and QDMTT.

The theoretical discussion of individual topics is complemented by case studies, examples or group discussions meant to apply the theory in practice. 

Our well-respected speakers include those from the most prestigious law firms and Big Four accounting firms, as well as from public service.

Topics Covered

  • From financial accounting to GloBE income or loss
  • Deferred taxes
  • Additional current top-up tax
  • Reorganisations and transitional rules
  • Data collection and tax-audit collaboration
  • Joint ventures, minority-owned constituent entities, partially-owned parent entities
  • CFC and other cross-border taxes
  • Flow-through entities, hybrid entities, PEs
  • Tax credits, tax equity structures, QFTBs
  • Investment funds
  • STTR
  • Safe harbour rules
  • The interaction of GloBE rules with the existing legal framework
  • The organization of GloBE at jurisdiction and OECD level

Learning Objectives

After this masterclass, the participants will: 

  • have gained a deep understanding of the GloBE Rules in their complicated interaction, and 
  • will have learned to apply these rules in practice


Hans Pijl
IBFD, The Netherlands
Willem-Jan van Veen 
Tax Administration and OECD delegate, The Netherlands
Robbert Hoyng
KPMG, The Netherlands
Jan Moret
KPMG, The Netherlands
Carlos Gutierrez
IBFD, The Netherlands
Andreas Perdelwitz
IBFD, The Netherlands
Francesco de Lillo
IBFD, The Netherlands
Alessandro Turina
IBFD, The Netherlands
Shee Boon Law
Independent Tax Consultant, The Netherlands

Field of study


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 advanced-level course. Participants taking this course will be expected to have a good understanding of the basic concepts of the GloBE Rules. Those who do not meet this requirement are recommended to follow IBFD’s online course on the Fundamentals of GloBE Rules – Pillar Two (to be launched in April/May 2024).

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 CPE on the National Registry of CPE Sponsors. State boards of accountancy have the final authority on the acceptance of individual courses for CPE credit. Issues 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: TBA

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.


The course will be held at IBFD headquarters in Amsterdam (Rietlandpark 301, 1019DW, Amsterdam, The Netherlands) or at an external venue in Amsterdam within easy reach from IBFD.

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


  • The programme of the masterclass is subject to minor changes, and IBFD reserves the right to apply changes to the line-up of speakers.
  • IBFD reserves the right to cancel the masterclass due to low registrations. If the minimum number of participants is not met and IBFD decides to cancel the masterclass, we will inform participants by 3 June 2024 at the latest. In that unfortunate case, 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, in the event that IBFD cancels the masterclass due to low registrations by 3 June 2024. 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.