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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 course presented over two-half days in a virtual class from 9:30am to 1:00pm UK time

Part One

BEPS 1.0

Module One considers the legislative changes that arose from the original implementation of the BEPS process 2017 to 2022.

Double Tax Agreements

The impact of the multi-lateral 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 look at the effect of the Principal Purpose Test (PPT) in combatting 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.
  • A discussion of pricing models and generally accepted practices and how they differ across the OECD countries.

Resident and Permanent Establishment

There have been changes to the definition of Permanent Establishment which are examined. We also look at residence issues as a result of the Development Securities case and the 2023 HMRC guidance on Nomad employees creating P/E’s

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)

It will also look at 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, the course will look at the practical implications for companies and their advisers arising from these changes. These include the dataset required to comply with Pillar 2 obligations.

Redcliffe's International Tax Principles & Pilar 2 courses are led by an accomplished tax professional and Director of a specialist consultancy firm focusing on taxation, share schemes, and reward strategies. He has designed bespoke share scheme services for SMEs and offers high-level advisory services to FTSE-listed companies on matters of communication and taxation. His expertise spans the full spectrum of Direct Taxation, with a keen interest in employment taxation and transfer pricing—both of which present complex, conceptual challenges. This prominent mix of expertise and attentiveness permeates through his engaging R&D workshops.

With nearly nine years at Henderson, where he managed the Share Schemes team, he gained significant industry experience. His qualifications include a CIPD Level 7 Masters, achieved during his tenure. Before this, while at Australian Mutual Provident (AMP), he played an instrumental role in creating one of the UK’s earliest Share Incentive Plans (SIP), so ground-breaking that HMRC reached out to him for guidance on encouraging wider corporate adoption.

The trainer’s 16-year career in taxation also includes senior roles in three of the "Big Four" firms, culminating in a Senior Manager position at Deloitte. His work covered a broad array of issues, including profit-related pay, expatriate tax, share schemes, reward management, US taxation, and corporate tax.

When he's not delivering expert tax courses and tax training, he enjoys cricket, history, skiing, tennis, and gardening. His passion for history also translates into giving lectures, where he keeps his presentation skills sharp, up-to-date and engaging. This distinct level of enthusiasm, passion and expertise is what he brings to each-and-every session, ensuring that participants gain valuable insights, understanding and knowledge.

This course is designed to provide participants with a solid foundation in the principles of international taxation, alongside an in-depth 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.

Participants will gain critical insights into the complexities of these changes, including the unique implementation challenges across over 140 countries that have adopted the Inclusive Framework.

This course stands out as one of the few training programs focused on the intricacies of Pillar 2. While the subject is complex and still evolving, our curriculum uniquely contextualises Pillar 2 within the broader landscape of international taxation. Participants will not only understand the foundations of international tax principles but will also gain an informed perspective on how the global minimum tax rules are shaping the tax strategies of some multinational enterprises.

By embedding Pillar 2 within its international tax context, this course helps attendees grasp the rationale behind the changes. The interactive structure—featuring questions, case studies, and discussions—ensures that participants can explore these topics in depth, enhancing both understanding and retention. This approach is designed to empower tax professionals and advisors to confidently address the implications of Pillar 2 for their clients or organisations.

This course is tailored for tax professionals, international finance experts, and in-house tax teams tasked with navigating complex international tax issues.

Ideal for those involved in advising multinational corporations, it equips attendees with the latest knowledge and tools to handle Pillar 2 requirements.

If you seek a strategic understanding of international tax and the Pillar 2 framework, this course provides essential guidance to stay ahead of these global tax developments

This two-module course is crafted to provide an understanding of both foundational international tax principles and the details of Pillar 2. The structured format allows participants to build from fundamental concepts to advanced insights, ensuring they leave equipped to address both current and emerging challenges in global tax compliance.

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£ 1390.00

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