Pillar Two Implementation – Impact Assessment, Compliance and Planning Beyond Global Minimum Taxes
The OECD/G20 BEPS Pillar Two Global Minimum Tax (GMT) represents a major shift in international corporate taxation. As jurisdictions implement the 15% minimum effective tax rate and the side‑by‑side agreement, multinational groups and tax authorities must adapt to a fast‑changing and highly technical compliance landscape.
This three‑day in‑person Masterclass offers practical, hands‑on guidance on applying the Global Anti‑Base Erosion (GloBE) Rules. Participants explore how the IIR, UTPR and QDMTT work in practice, how the rules interact, and how different countries implement them. The course also covers the relevance of key safe harbours and their role in reducing compliance burdens.
The programme strongly focuses on operational readiness. Participants learn how to prepare GloBE information returns, manage data requirements, and build internal processes for consistent global compliance. The Masterclass also explores how Pillar Two affects common holding, financing, IP and supply‑chain structures. Beyond this, the Masterclass considers the broader impact of GMT on tax incentives, qualified refundable tax credits, tax competition and M&A transactions, while highlighting emerging risk areas and dispute‑resolution options.
Designed for professionals with a basic understanding of the GloBE framework, this intermediate‑level course strengthens participants’ ability to apply the rules, develop effective compliance strategies and navigate the post‑GMT environment with confidence.
Claim your 10% early‑bird discount before 10 April 2026
Scope of OECD GloBE rules
Impact assessment of GMT rules
- Application of IIR, QDMTT and UTPR
- Potential impact on international tax planning structures
- Implementation of the side-by-side arrangement
Global developments on Pillar 2 implementation
Pillar 2 compliance
- Application of Transitional CbCR safe harbours
- Application of side-by-side safe harbour and UPE safe harbour
- Application of substance-based tax incentive safe harbour
- Application of simplified ETR safe harbour
- GloBE information returns and compliance obligations
Post Pillar 2 international tax landscape:
- Tax competition and tax incentives
- Mergers and acquisition and intragroup transfers
- Disputes and disputes management
After this masterclass, the participants will be able to:
- Apply the complex GloBE rules to specific examples, cases and real-life scenarios.
- Assess the impact of various elements in the application of GloBE minimum taxes, e.g. IIR, UTPR and QDMTT, the order of their application and their application to common international tax planning structures – e.g. holding, financing, IP and supply chain structures.
- Develop strategies to comply with GMT obligations around the globe, including through the application of transitional and permanent safe harbours.
- Identify the impact of QDMTT and navigate changes and strategies for dealing with tax competition and incentive regimes in the post-GMT era.
- Evaluate the impact of GMT on M&A transactions and changes that need to be made in M&A due diligence.
- Identify potential areas of disputes and dispute management options.
- Shee Boon Law, IBFD, Independent Tax Consultant
- Carlos Gutiérrez Puente, IBFD, Senior Principal Associate
Others to be confirmed...
The course is suitable for government staff, tax advisers, lawyers, accountants, in‑house tax directors, controllers, finance staff, and corporate tax experts.
The Masterclass will take place at an exclusive venue in Dubai. Final location details will be confirmed soon.
This is an intermediate-level course. Participants taking this course will be expected to understand 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. Alternatively, participants may wish to attend the Fundamentals course on GMT in Amsterdam, scheduled for 14-16 April 2026 prior to attending this intermediate level course.
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
See our FAQ section for more information. Regarding administrative policies such as complaint, cancellation or refund, please refer to our Terms and Conditions or please contact us via email.
Field of Study - Taxes
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. Considering 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.
Group Participation
If you are an enterprise and would like to register a group of more than 5 participants from your company, please email us at info@ibfd.org for more details.
