OECD Pillar Two Global Minimum Tax Implementation Training Course

Course overview

Multinational groups within the OECD Pillar Two scope must turn a rules-based global minimum tax framework into repeatable data, calculation, filing and governance processes. This is difficult because the GloBE effective tax rate is calculated jurisdiction by jurisdiction, using financial accounting data adjusted under the Model Rules rather than statutory tax computations alone. Finance and tax teams must identify constituent entities, map ownership chains, test EUR 750 million revenue scope, reconcile covered taxes, assess qualified domestic minimum top-up taxes (QDMTTs), and determine which entity bears any residual top-up tax under the Income Inclusion Rule (IIR) or Undertaxed Profits Rule (UTPR).

This five-day course teaches participants to apply the OECD Pillar Two framework from initial scoping through GloBE Information Return preparation. Participants work through the GloBE tax base, adjusted covered taxes, jurisdictional ETR, substance-based income exclusion, top-up tax percentage, de minimis exclusion, safe harbours, transitional rules and rule-ordering mechanics. They learn how to build a jurisdiction-level calculation model, distinguish permanent from temporary differences, assess tax incentive effects, document key elections, and create an implementation roadmap aligned to the group’s reporting calendar and control environment.

Instruction combines expert-led technical sessions with spreadsheet-based calculations, a multinational case study and facilitated design workshops. Teams use a structured Pillar Two data-request pack, calculation workbook and governance checklist to solve realistic issues involving deferred tax, intra-group arrangements, QDMTTs and incomplete data. Each participant leaves with a completed Pillar Two implementation blueprint: a scoped entity map, data-gap register, calculation workflow, filing calendar, responsibility matrix and prioritized action plan that can be adapted for their organisation.

The course is designed for tax, finance, controllership and reporting professionals supporting multinational groups, including advisers who need to explain Pillar Two calculations and implementation choices to clients and senior stakeholders.

Course objectives

By the end of this course, participants will be able to:

• Determine group scope and identify constituent entities using the EUR 750 million consolidated revenue test and ownership analysis
• Construct a jurisdictional GloBE ETR calculation using GloBE income or loss and adjusted covered taxes
• Reconcile current and deferred tax data to the Pillar Two covered-tax and recast deferred-tax requirements
• Calculate substance-based income exclusions, excess profit and jurisdictional top-up tax
• Apply the IIR, QDMTT and UTPR rule order to allocate top-up tax liability across a group structure
• Evaluate transitional CbCR Safe Harbour, de minimis exclusion and key Pillar Two elections for a jurisdiction
• Prepare a Pillar Two data-request pack and GloBE Information Return evidence schedule
• Develop a phased implementation roadmap with controls, ownership assignments, milestones and escalation points

Benefits of attending

Target competencies

Who should attend

• International Tax Managers — who must interpret Pillar Two rules and coordinate group-wide implementation
• Group Tax Directors — who need defensible decisions on exposure, elections, governance and external reporting
• Tax Accounting Managers — who reconcile tax provision data, deferred taxes and covered-tax adjustments
• Financial Controllers — who own legal-entity reporting data and control the quality of Pillar Two inputs
• Transfer Pricing Managers — who assess how intercompany arrangements and tax incentives affect jurisdictional outcomes
• Tax Advisory Professionals — who support clients with Pillar Two scoping, calculations and implementation plans

Requirements and prerequisites

Participants should have working knowledge of corporate income tax, consolidated financial statements and legal-entity reporting within a multinational group. Familiarity with tax provision concepts, current tax, deferred tax and effective tax rate analysis is assumed, as is confidence using Microsoft Excel for structured calculations. Experience with country-by-country reporting, ERP extracts or tax reporting systems is helpful but not essential. Participants do not need prior Pillar Two implementation experience, specialist tax software or programming skills. This is not a basic corporate tax course; complete newcomers should first build grounding in corporate tax and financial reporting.

Training methodology

The course uses short technical briefings followed by instructor-guided application in a single multinational group case. Participants map entities and ownership, populate a GloBE calculation workbook, reconcile tax provision data, test safe-harbour eligibility and allocate top-up tax under the IIR, QDMTT and UTPR. Facilitated group reviews focus on judgement calls, source-data limitations and audit evidence rather than memorising rule text. On the final day, participants convert the case findings into an implementation plan with accountable owners, control points, system dependencies and reporting deadlines.

Course outline

Day 1: Pillar Two framework, scope and operating model

• OECD GloBE Model Rules architecture and policy objectives
• EUR 750 million consolidated revenue scope test
• Ultimate parent entity and constituent entity identification
• Excluded entities, permanent establishments and transparent entities
• Jurisdictional blending and the GloBE tax base
• IIR, QDMTT and UTPR rule hierarchy
• Pillar Two implementation governance and data-source mapping

Workshop: Participants create an entity scope map for a multinational case group and identify the jurisdictions, ownership links and data owners requiring further analysis.

Day 2: Calculating GloBE income and adjusted covered taxes

• Financial accounting net income or loss as the GloBE starting point
• GloBE income adjustments for excluded dividends and equity gains
• Treatment of policy-disallowed expenses and prior-period errors
• Current tax expense and covered-tax eligibility
• Deferred tax recasting at the minimum tax rate
• Allocation of taxes among permanent establishments and constituent entities
• Jurisdictional ETR calculation workbook design

Workshop: Participants populate a jurisdictional calculation workbook and produce a documented GloBE income, adjusted covered-tax and ETR reconciliation.

Day 3: Top-up tax, exclusions and safe harbours

• Minimum tax rate and jurisdictional top-up tax percentage
• Substance-based income exclusion for payroll and tangible assets
• Excess profit and additional current top-up tax
• De minimis exclusion election and testing
• Transitional CbCR Safe Harbour simplified calculations
• Tax incentives, refundable credits and ETR volatility
• QDMTT design considerations and qualified status assessment

Workshop: Participants test three jurisdictions for safe-harbour eligibility, calculate remaining top-up tax and record the assumptions supporting each result.

Day 4: Rule ordering, compliance and reporting evidence

• IIR application to low-taxed constituent entities
• QDMTT crediting and allocation mechanics
• UTPR allocation key and residual top-up tax
• GloBE Information Return data fields and filing responsibilities
• Notification obligations and local return coordination
• Transitional rules, elections and record-retention requirements
• Control design for source data, review and sign-off

Workshop: Participants complete a rule-ordering case and prepare a GloBE Information Return evidence schedule showing data source, owner, review control and retention support.

Day 5: Implementation planning and management reporting

• Pillar Two readiness assessment and gap-register method
• Data extraction requirements from consolidation and tax provision systems
• Spreadsheet, tax engine and ERP integration options
• Calculation process calendar and close-cycle dependencies
• Roles and responsibilities using a Pillar Two RACI matrix
• Scenario modelling for cash-tax and financial-statement impact
• Executive reporting, governance escalation and implementation milestones

Workshop: Participants produce a tailored Pillar Two implementation blueprint containing a data-gap register, RACI matrix, milestone plan and executive decision paper.

Tools & standards covered

OECD GloBE Model Rules, OECD GloBE Information Return, Microsoft Excel, Thomson Reuters ONESOURCE Pillar Two

A typical training day

Live online deliveries follow the same structure in the East Africa Time zone, with shorter screen blocks and longer breaks.

What the fee includes

How you can take this course

Certification

Participants who complete the full five days receive the Skillset Development Certificate of Completion, stating the course title, course code, dates and delivery format — suitable for professional-development records and employer reimbursement.

Frequently asked questions