COURSE OVERVIEW

This highly-interactive course includes various practical sessions and exercises. Theory learnt will be applied using the “MS Excel” application.

This course is designed to provide participants with a detailed and up-to-date overview of Navigating Global Implementation of Pillar Two Minimum Tax Rules: Impact Assessment, Planning and Compliance. It covers the global tax reform background, OECD inclusive framework and global anti-base erosion (GloBE) rules; the key components of the GloBE rules, scoping and thresholds and timeline for global implementation; and the GloBE income, covered taxes, taxes excluded from ETR, treatment of tax credits and deferred taxes and impact of timing differences.

Further, the course will also discuss the effective tax rate (ETR) computation; the top-up tax calculation and allocation; the substance-based carve-outs, entity classification and ownership structures and interaction with domestic and international tax laws; the group structuring and reorganization strategies covering restructuring to manage pillar two exposure, jurisdictional planning and entity consolidation; and the use of QDMTTs to mitigate UTPR risk and substance relocation and investment decisions.

During this interactive course, participants will learn the accounting and disclosure implications, technology, data and system readiness and tax planning in a pillar two world; using qualified domestic minimum top-up taxes (QDMTT) and safe harbors and simplified calculations; the operational and treasury considerations, governance and risk management and compliance and filing requirements; the GloBE information return and data collection, jurisdictional implementation updates and future of international tax frameworks; anticipating tax authority inquiries and preparing documentation for audit defense; and the mutual agreement procedures (MAP) and cross-border controversy management.