Explain the structure of the GloBE rules, including the income inclusion rule, the undertaxed profits rule and qualified domestic minimum top-up taxes.
Finance & Banking
OECD Pillar Two Global Minimum Tax Compliance for Multinational Groups
Prepares group tax and finance teams to calculate jurisdictional effective tax rates, apply the income inclusion and top-up tax rules, and prepare GloBE information returns under Pillar Two.
🗓️Duration5 training days
📚Content4 modules · 8 sessions
🎓On completionAccredited attendance certificate
About the programme
Course Overview
Pillar Two changes the question a group tax function has to answer every year from what rate applies in each jurisdiction to what the effective rate becomes once every covered tax and every adjustment required by the GloBE rules is applied, and whether that rate clears the internationally agreed minimum. Groups now have to collect constituent entity data that finance systems were never built to produce, run jurisdictional effective tax rate calculations under the income inclusion rule, the undertaxed profits rule and qualified domestic minimum top-up taxes, and be ready to justify every figure in a GloBE information return. This course works through the mechanics of GloBE income and covered tax adjustments, the substance-based income exclusion for payroll and tangible assets, and the transitional safe harbours that reduce the calculation burden in lower-risk jurisdictions. Participants build a jurisdictional top-up tax calculation from trial balance data, identify where existing systems and data will not support the required granularity, and prepare disclosure and provisioning positions that finance, tax and audit teams can all defend.
Expected Learning Outcomes
Calculate jurisdictional effective tax rates from GloBE income and covered tax adjustments.
Apply the substance-based income exclusion for payroll costs and tangible asset carve-outs.
Assess eligibility for transitional country-by-country reporting safe harbours.
Identify data and system gaps that prevent existing finance processes from supporting Pillar Two calculations.
Prepare a GloBE information return with supporting jurisdictional workings.
Determine top-up tax allocation and payment obligations across constituent entities.
Who Should Attend
Group tax managers and directors responsible for Pillar Two compliance.
Finance and reporting teams preparing jurisdictional tax data for multinational groups.
Tax advisers supporting multinational clients through GloBE implementation.
Financial controllers integrating Pillar Two data requirements into existing systems.
Internal audit and risk teams reviewing global minimum tax provisioning.
CFOs and finance directors overseeing multinational group tax risk.
Course Modules
Select any module to see its sessions and points.
01Foundations of the GloBE Rules
2 sessions · 8 points
Session 1Scope and Architecture of Pillar Two
- Identify which groups fall within scope of the GloBE rules based on consolidated revenue thresholds.
- Explain how the income inclusion rule, undertaxed profits rule and qualified domestic minimum top-up tax interact.
- Map constituent entities, joint ventures and minority-owned entities into the group's GloBE structure.
- Assess jurisdictional ordering rules that determine which mechanism collects any top-up tax due.
Session 2GloBE Income, Loss and Covered Taxes
- Reconcile financial accounting income to GloBE income using required adjustments and exclusions.
- Classify covered taxes and identify adjustments for deferred tax and uncertain tax positions.
- Apply loss carry-forward and cross-border allocation rules within the GloBE income calculation.
- Identify permanent and temporary differences that most commonly distort jurisdictional calculations.
02Calculating the Effective Tax Rate and Top-Up Tax
2 sessions · 8 points
Session 1Jurisdictional Effective Tax Rate Calculation
- Calculate jurisdictional effective tax rates by dividing adjusted covered taxes by net GloBE income.
- Apply the substance-based income exclusion using payroll and tangible asset carve-out formulas.
- Identify blending rules for jurisdictions with multiple constituent entities and mixed results.
- Assess the impact of tax incentives and credits on the jurisdictional effective tax rate outcome.
Session 2Top-Up Tax Computation and Allocation
- Compute the top-up tax percentage and amount for jurisdictions below the minimum rate.
- Allocate top-up tax liability across constituent entities and parent entities under GloBE ordering rules.
- Apply qualified domestic minimum top-up tax mechanics to retain taxing rights locally.
- Assess interaction between top-up tax and existing controlled foreign company regimes.
03Safe Harbours, Data and System Readiness
2 sessions · 8 points
Session 1Transitional and Permanent Safe Harbours
- Assess eligibility for the transitional country-by-country reporting safe harbour by jurisdiction.
- Apply de minimis, routine profits and effective tax rate tests within the safe harbour framework.
- Identify circumstances where safe harbour relief is lost in a later reporting period.
- Evaluate simplified calculation approaches available for lower-risk jurisdictions.
Session 2Data Collection and Systems Readiness
- Map data requirements for GloBE calculations against existing enterprise resource planning and tax systems.
- Identify constituent entity data gaps in payroll, fixed asset and tax provision records.
- Design a data governance process that assigns ownership for each required GloBE data point.
- Assess build, buy or outsource options for Pillar Two calculation and reporting technology.
04Compliance, Reporting and Governance
2 sessions · 8 points
Session 1Preparing the GloBE Information Return
- Prepare a GloBE information return with jurisdictional workings and supporting documentation.
- Apply filing and exchange mechanisms for groups with multiple constituent entities across jurisdictions.
- Reconcile GloBE information return figures with statutory accounts and tax provisioning.
- Identify penalty and safe harbour transitional relief provisions relevant to filing errors.
Session 2Provisioning, Disclosure and Governance
- Apply the deferred tax accounting exception relevant to Pillar Two top-up tax provisioning.
- Draft financial statement disclosures that explain top-up tax exposure to investors and auditors.
- Coordinate Pillar Two governance across group tax, finance, treasury and legal functions.
- Establish a monitoring process for legislative changes as jurisdictions implement GloBE rules.
What the participant receives
4 course modules
A structured syllabus
8 training sessions
across 5 days
32 detailed points
Applied, detailed content
Accredited attendance certificate
On completing the programme
Complete your registration
We will contact you within one business day to confirm.
Ready to start?
Reserve your seat and start building the skill.