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

• Analyze the limitations of traditional tax nexus and profit attribution rules in the digital era.
• Evaluate the economic concepts of value creation by digital businesses, including user participation.
• Compare and contrast unilateral measures (e.g., DSTs) and their compliance/policy implications.
• Understand the mechanics and scope of the OECD Pillar One proposal for new taxing rights (Amount A).
• Describe the framework and potential impact of the OECD Pillar Two global minimum tax rules (GloBE).
• Assess the challenges of implementing new rules for highly digitalized businesses in domestic law.
• Identify planning and compliance issues related to digital permanent establishments (PEs).
• Advise on the strategic implications of global consensus on the taxation of the digital economy.

• International Tax Policy Analysts and Advisors
• Tax Lawyers and Consultants specializing in Cross-Border E-commerce
• Tax Directors and Managers of Multinational Digital Companies (MNCs)
• Government Officials involved in Tax Treaty Negotiation
• Tax Auditors specializing in Intangibles and Digital Business Models
• Economists specializing in Public Finance and Digital Markets

• Case studies on the application of Pillar One Amount A to large MNEs (Group Activity).
• Quantitative exercises on calculating the Effective Tax Rate (ETR) under Pillar Two.
• Policy debate on the merits of a global minimum tax vs. tax competition.
• Workshops on interpreting complex OECD Model Rules (Individual Exercises).
• Simulated treaty negotiation to adopt new taxing rights.

Unit 1: Challenges of Digitalization for Tax

• The concept of "nexus" and its reliance on physical presence (Permanent Establishment)
• Flaws in profit attribution methods for intangible assets and remote services
• Defining value creation in a digital business (user data, network effects)
• The shift from source principle to market jurisdiction

• Analysis of Digital Service Taxes (DSTs): structure, scope, and rationale
• Policy conflicts arising from unilateral measures
• The US response and trade implications of DSTs

Unit 2: Pillar One: New Taxing Rights

• The scope: defining MNEs subject to Amount A (revenue and profitability thresholds)
• The calculation: determining the residual profit for reallocation
• The allocation key: apportionment based on market jurisdiction revenue
• Administration, tax certainty, and the new dispute resolution mechanism

Unit 3: Pillar Two: Global Minimum Tax

• The Income Inclusion Rule (IIR) and the Undertaxed Payments Rule (UTPR)
• Scope and thresholds for MNE groups subject to Pillar Two
• Calculating the Effective Tax Rate (ETR) per jurisdiction (jurisdictional blending)
• The carve-outs and exceptions (e.g., substance-based income exclusion)

Unit 4: Implementation and Compliance Issues

• Integrating Pillar One and Pillar Two into domestic tax law and tax treaties
• Interplay between the new rules and existing BEPS minimum standards
• Compliance burden and data requirements for MNEs under the new regime
• The role of tax administrations in complex tax base calculations (Amount A/ETR)

Unit 5: Strategic Impact and Future Trends

• Assessing the impact of Pillar Two on corporate structuring and location decisions
• Transfer pricing adjustments and the minimum tax rules
• Scenario analysis of the combined impact of Pillars One and Two on tax liabilities