Pillar Two - Fundamentals and Practice
When: Thursday, September 17, 2026 - Friday, December 18, 2026, 2:00 PM - 5:00 PM
Where: Online
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Master the rules and practical implications of Pillar Two and how to use them in tax planning.
The Centre for Commercial Law Studies, Queen Mary University of London, is pleased to offer an Executive Education course on the fundamentals and practice of Pillar Two, in collaboration with STI Taxand and WTL. The course can be used in preparation for the CIOT’s Pillar Two Award, as the syllabus is specifically designed for candidates sitting the December 2026 examination.
The course provides a structured, syllabus-driven and practice-oriented approach to the OECD Global Anti-Base Erosion (GloBE) Rules, equipping participants with the technical depth, computational skills and interpretative capability required to succeed in the Pillar Two Award and to apply Pillar Two rules confidently in real-world multinational contexts.
The course reflects the full scope and weighting of the Pillar Two Award syllabus, combining academic rigour with the practical insights of leading international tax practitioners.
This course will offer live-online seminars with leading experts, which will be recorded and available in your study materials. The study materials will also include slides, handouts, exam practice questions and revision notes.
A certificate of attendance will be provided.
Key information
When: The course is taught on Thursdays, 14.00-17.00 BST
- Day 1 Thursday 17/09
- Day 2 Thursday 24/09
- Day 3 Thursday 01/10
- Day 4 Thursday 08/10
- Day 5 Thursday 15/10
- Day 6 Thursday 22/10
- Day 7 Thursday 29/10
- Day 8 Thursday 05/11
- Day 9 Thursday 12/11
- Day 10 Thursday 19/11
- Revision Day 1 Thursday 26/11
- Revision Day 2 Thursday 03/12
- Revision Day 3 Thursday 10/12
- Exam date: Friday 18/12
Location: Online
Fee:
- Early Bird Rate: £2,600 + VAT (until 1st September 2026)
- Standard Rate: £2,900 + VAT (from 1st September 2026)
We are pleased to offer a 10% discount for QMUL alumni.
A group discount of 20% is available to organisations registering 3 or more people. Please get in touch for further information.
A discount of 20% is available to those who do not wish to sit for the Pillar Two Award and do the three revision classes.
A certificate of completion will be provided to participants upon conclusion of the course. Please note that registration to the CIOT and the examination fees for the Pillar Two Award are not included in our course fees. It is the candidates' responsibility to register with the CIOT and pay for any examination fees.
Syllabus and Topics Covered
The course fully covers the Pillar Two Award Syllabus, including all examinable areas:
- Scope of the GloBE Rules
- MNE groups, constituent entities, excluded entities.
- Ultimate Parent Entities and consolidated revenue threshold
- Charging Provisions
- Income Inclusion Rule (IIR)
- Undertaxed Profits Rule (UTPR)
- Ordering rules and allocation of top-up tax
- Computation of GloBE Income or Loss
- Financial accounting starting point.
- Adjustments, permanent establishments and flow-through entities
- Adjusted Covered Taxes
- Definition and allocation of covered taxes
- Temporary differences and post-filing adjustments
- Effective Tax Rate and Top-Up Tax
- ETR calculation mechanics
- Substance-based income exclusion
- De minimis exclusion and QDMTT
- Corporate Restructurings and Holding Structures
- Mergers, demergers, joint ventures and multi-parented groups
- Distribution regimes and tax neutrality rules
- Administration, Safe Harbours and Transition Rules
- Filing obligations and GloBE Information Return
- Transitional CbCR safe harbours
- Deferred tax adjustments and transitional reliefs
- Subject to Tax Rule (STTR)
- Inclusive Framework Policies and Governance
Learning Objectives
By the end of the course, participants will be able to:
- Demonstrate detailed and advanced knowledge of the Pillar Two GloBE Rules across all syllabus areas.
- Apply Pillar Two rules in written and computational exam-style scenarios.
- Analyse complex fact patterns involving ETR calculations, top-up tax and allocation mechanisms.
- Identify and resolve issues arising from group restructurings, hybrid entities and transitional rules.
- Confidently approach the CIOT Pillar Two Award examination with a structured exam strategy
Who is it for?
This course is designed for new and experienced international tax professionals alike:
- International tax advisers and lawyers
- In-house tax professionals of multinational groups
- International Tax & Transfer pricing and tax policy specialists
- Professionals preparing for the CIOT Pillar Two Award
- Individuals seeking deep technical competence in Pillar Two
CIOT Pillar Two Award – Further Information
You can find below the most important information: