Tax

OECD Two-Pillar Tax Reform: Pillar One and Pillar Two

Understand how the two pillars fit together through a practical multinational case.

2 CPD credits on completion
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Certificate on completion
Downloadable resources
Self-paced learning

About This Course

Build a connected understanding of the OECD’s two-pillar tax framework. Follow Meridian Group, a single multinational case used throughout the course, to explore scope, market jurisdictions, profit reallocation and global minimum tax.

Work through Amount A nexus and revenue sourcing, compare Amount A and Amount B, and examine the GloBE top-up tax framework. The course also covers the interaction of QDMTT, IIR and UTPR, the Transitional CbCR Safe Harbour and the GloBE Information Return filing position.

Course format and CPD

This course provides 2 units of CPD. Narrated videos, worked examples and knowledge checks support the Pillar One and Pillar Two lessons, followed by a final assessment using fresh facts and a wrap-up.

Course outline

  1. Introduction
  2. Pillar One
  3. Pillar Two
  4. Final Assessment
  5. Wrap Up

Downloadable course companion

Download the fillable and printable worksheet to organise your notes on Pillar One and Pillar Two and record questions to revisit. This supplementary companion is separate from the LMS lessons and assessment and does not add CPD credits.

Course companion worksheet (PDF)

What You Will Learn

  • Explain what Pillar One and Pillar Two do, and identify which groups are in scope for each.
  • Apply the Amount A nexus test and revenue sourcing rules to attribute group revenue to market jurisdictions.
  • Calculate the Amount A reallocation to a market jurisdiction, and contrast it with the Amount B return.
  • Analyse how the GloBE rules produce a top-up tax and how QDMTT, IIR and UTPR are ordered.
  • Apply the Transitional CbCR Safe Harbour tests, and set out the GloBE Information Return filing position.

Who This Course Is For

  • Group tax teams assessing how Pillar One and Pillar Two affect multinational groups.
  • Controllers and CFO teams seeking a connected overview of the two-pillar framework.
  • Tax and finance advisers supporting cross-border businesses.

Frequently Asked Questions

Course Details

CPD Credits2
CertificateYes

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CPD certificate on completion
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Self-paced learning
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