Upon completion of this course, participants will be able to:

• Master the technical scope and jurisdictional application rules of both Pillar One (Amount A) and Pillar Two (GloBE Rules).
• Perform the complex calculation of the ETR for MNEs under the GloBE rules, including jurisdictional blending.
• Apply the carve-outs and exceptions (e.g., substance-based income exclusion) to the Pillar Two calculation.
• Understand the mechanics of the Income Inclusion Rule (IIR) and the Undertaxed Payments Rule (UTPR) implementation.
• Analyze the data requirements and IT system changes necessary for compliance with the GloBE Information Return (GIR).
• Work through a case study demonstrating the new profit allocation under Pillar One Amount A.
• Evaluate the impact of the new rules on tax structuring, transfer pricing, and M&A decisions.
• Advise management on the compliance risks and strategic options in the BEPS 2.0 implementation phase.

• Senior International Tax Managers and Directors (MNEs)
• Chief Financial Officers (CFOs) and Group Tax Heads
• International Tax Consultants and Specialists
• Tax Lawyers and Policy Advisors working on BEPS 2.0 Legislation
• Tax Auditors and Compliance Officers for Large Taxpayer Offices
• IT and Data Professionals for Tax Technology Implementation

• Extensive quantitative case studies on calculating Pillar Two ETR and Top-up Tax for a simulated MNE (Individual & Group Work).
• Hands-on exercise: mapping required Pillar Two data points to financial statements.
• Scenario analysis of corporate restructuring decisions under the influence of Pillar Two.
• Discussions on the practical challenges of data collection for the GloBE Information Return (GIR).
• Presentation: Advising a CFO on the expected tax liability increase under BEPS 2.0.

Unit 1: Technical Framework of Pillar Two (GloBE)

• Defining the MNE Group and the €750 million revenue threshold
• The cascading mechanism: IIR as the primary rule, UTPR as the backstop
• The Qualified Domestic Minimum Top-up Tax (QDMTT) and its impact
• Transitional rules and safe harbors (e.g., transitional CbCR safe harbor)

• Defining GloBE Income/Loss (starting from financial accounting standards)
• Defining Covered Taxes (adjustments to financial accounting tax expense)
• Calculating the Adjusted Covered Taxes and GloBE ETR (jurisdiction by jurisdiction)

Unit 2: Pillar Two Carve-Outs and Implementation

• The purpose and application of the routine return on tangible assets and payroll costs
• Calculating and utilizing the SBIE to reduce the Top-up Tax amount
• Transitional phase-in rules for the SBIE

• The GloBE Information Return (GIR): required data points and format
• Data gap analysis and integrating financial reporting systems with tax compliance
• The role of the OECD Implementation Framework and administrative guidance

Unit 3: Technical Framework of Pillar One (Amount A)

• Defining MNEs subject to Amount A (higher revenue and profitability thresholds)
• The new nexus rule based on sales and domestic revenue thresholds
• Exclusions: extractive industries and regulated financial services

• Defining the *profit before tax* and the *deemed routine profit*
• The calculation of the *residual profit* for reallocation (Amount A)
• Apportionment rules: allocating Amount A to market jurisdictions based on revenue

Unit 4: Operationalizing the New Rules

• Impact analysis of BEPS 2.0 on ERP and tax provision systems
• Developing data models to capture the necessary granular financial and tax data
• Utilizing Tax Technology (TaxTech) solutions for automation and reporting

• Reviewing existing group structures for Pillar Two optimization and exposure
• Interaction of Pillar One with existing Transfer Pricing methods and APAs
• Tax treaty implications and the Multilateral Convention (MLC) for Pillar One

Unit 5: Controversy and Transition

• The new mandatory and binding dispute resolution mechanism under Pillar One
• Potential for controversies and disputes under the Pillar Two rules
• Managing the compliance burden during the multi-year transitional period