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International Tax Principles and Pillar 2 (The Global Corporate Minimum Tax Rate)

Explore international tax principles and the global minimum tax under Pillar 2, equipping tax professionals to navigate compliance challenges for multinational entities

Green and Red leaves a contrast of color that is both vibrant and calming

A one-day international tax training presented over two-half days in a virtual class

In-house pricing available – often more cost-effective for teams of 10+
pdf Download:   Course Outline

  • Develop a strong understanding of the regulatory and legislative framework behind international tax principles and Pillar 2 rules
  • Improve cross-border tax compliance by learning how multinational companies must adapt to the rules
  • Understand the implications of BEPS reforms, transfer pricing changes, and Pillar 2 implementation

Part One

BEPS 1.0

Module One of Redcliffe’s international tax training courses considers the legislative changes that arose from the original implementation of the BEPS process from 2017 to 2022.

Double Tax Agreements

The impact of the multilateral instruments on double tax agreements across the world. In particular, the new rules on permanent establishments as well as the principal purpose test, which is designed to prohibit taxpayers from achieving double non-taxation.

We assess the effect of the Principal Purpose Test (PPT) in combating aggressive tax planning. 

Transfer Pricing

The course will include the following topics;
  • The changes to Transfer Pricing as a result of BEPS
  • The methods by which a company can defend its position
  • International tax training covers various pricing models and widely accepted practices, examining how they vary across OECD countries

Resident and Permanent Establishment

Changes to the definition of Permanent Establishment are examined in detail in this international tax planning course. Additionally, we explore residence issues arising from the Development Securities case, as well as the 2023 HMRC guidance on Nomad employees creating Permanent Establishments.

Part Two

BEPS 2.0

Module two will look at the Pillar 2 legislation in detail. This will include:
  • The income inclusion rule (IIR)
  • The undertaxed profits rule (UTPR)
  • The domestic minimum tax top-up (DMTTR)
  • The Subject to Tax Rule (STTR)
Pillar 2 training will also explore which organisations will be affected by the new rules and how they will need to deal with the transitional provisions over the next three years. It will also cover the safe harbour provisions, which companies may be able to use to reduce the administrative burden.

Finally, we will assess the practical implications of these changes for companies and their advisers, including the required dataset to meet Pillar 2 obligations, wrapping up international tax planning courses.

Redcliffe's International Taxation course specialist is an accomplished tax professional and Director of a specialist consultancy firm focused on taxation, share schemes, and reward strategies.

He has developed tailored share scheme services for SMEs and provides high-level advisory services to FTSE-listed companies on communication and taxation matters. His expertise covers the full spectrum of direct taxation, with a particular focus on employment taxation and transfer pricing—two areas that present complex, conceptual challenges.

Our highly skilled trainer provides in-depth insights into regulatory and legislative nuances of international taxation, drawing from years of hands-on experience.

With almost nine years at Henderson leading the Share Schemes team, he gained extensive experience in international taxation and earned a CIPD Level 7 Master's. Previously, at AMP, he helped develop one of the UK’s first Share Incentive Plans (SIP), which led to HMRC consulting him on strategies for broader adoption. Throughout his 16-year career in taxation, he has held senior positions at three of the 'Big Four' firms, ultimately becoming a Senior Manager at Deloitte.

His expertise spans profit-related pay, expatriate tax, share schemes, reward management, US taxation, and corporate tax. When our trainer is not conducting international tax and Pillar 2 training, he enjoys cricket, history, skiing, tennis, and gardening. His passion for history extends to giving lectures, keeping his presentation skills sharp, current, and engaging.

Redcliffe Training's international taxation course will equip you with a strong foundation in:
  • The principles of international taxation, coupled with a thorough understanding of the developments under Pillar 2.
  • As of accounting periods beginning on or after 31st December 2023, Pillar 2 mandates a minimum global tax rate of 15% for multinational entities. This historic change to global tax policy marks a significant shift, requiring an adaptive and nuanced approach to compliance across varied jurisdictions.
  • Critical insights into the complexities of these changes, including the unique implementation challenges across over 140 countries that have adopted the inclusive framework.
  • A thorough understanding of the regulatory and legislative framework covered in both the tax principles program and Pillar 2 training.

We have tailored this course for tax professionals, international finance experts, and in-house tax teams tasked with navigating complex international tax issues. It is specifically designed for:
  • Professionals who deal with cross-border tax planning, compliance, and strategy, including those in advisory roles for multinational corporations.
  • Professionals advising multinational companies, this course equips participants with the latest knowledge and tools to manage the evolving Pillar 2 requirements effectively.

Attendees will gain a deep understanding of the regulatory changes and practical strategies to ensure compliance with the global minimum tax rate and related developments. For those seeking a strategic understanding of international tax and the Pillar 2 framework, Redcliffe’s International Tax Principles and Pillar 2 training provide essential guidance to stay ahead of these global tax developments.

This two-module international tax training provides a thorough understanding of both foundational international tax principles and the detailed provisions of Pillar 2. Gain in-depth insights into:
  • Global tax frameworks
  • The evolving requirements of Pillar 2
  • How they impact multinational companies

The course offers practical strategies for navigating the complexities of compliance, ensuring attendees are well-prepared to address both current and future challenges in international taxation. The structured format guides participants from foundational concepts to advanced insights, ensuring you are well-prepared to address both present and future challenges in global tax compliance.

  • We have clients that come within the scope of Pillar 2, so we will be advising using the knowledge gained to assist them.
  • My expectations were to get a better understanding of the principles of Pillar II and what would be required from local entities within the group. Training was very well structured, with all important aspects of Pillar II covered. I am not a tax expert, but as we don't have a local tax team need to be involved in Pillar II compliance from the local entity level within the group. Now I have much clearer picture of all the steps and rules and how to approach to further knowledge building.
Number of places:

£ 1190.00

Discounts available:

  • 2 places at 20% less
  • 3 places at 30% less
  • 4+ places at 40% less
  • Select the number of course places and dates to automatically calculate the discount
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