Global Minimum Tax Implementation Post Side-by-Side Package – Impact Assessment, Compliance and Planning
Claim your 10% early‑bird discount before 23 October 2026. Your discount will be applied automatically at checkout when you register before the deadline.
This three-day Masterclass is designed to equip participants with the practical knowledge and confidence needed to understand, apply and manage the implications of GMT requirements in real-world situations. It goes beyond theory to focus on how the Global Anti-Base Erosion (GloBE) Rules operate in practice — and what they mean for multinational groups, advisors, tax officials and policymakers on a day-to-day basis.
Through interactive sessions, examples, case studies and group discussions, participants gain hands-on insight into the mechanics and impact of the Income Inclusion Rule (IIR), Undertaxed Payments Rule (UTPR) and Qualified Domestic Minimum Top-up Taxes (QDMTT). The course clarifies how these rules interact, the order in which they apply, and how different countries are implementing them — often with important local variations. Participants also explore how GMT rules apply to special entities and structures, and how transitional and permanent safe harbours, including the side-by-side safe harbour, UPE safe harbour, substance-based tax incentive safe harbour and the simplified effective tax rate safe harbour can be used to manage compliance and reduce administrative burdens.
A central focus of the Masterclass is on practical compliance and operational readiness, with participants learning how to prepare for and manage GloBE information returns, data collection, reporting and documentation, and how to design internal processes that support consistent, efficient global compliance.
The course also examines how Pillar Two affects common international tax planning structures such as holding companies, financing arrangements, intellectual property structures and global supply chains, and explores the strategic adjustments that may be required in response. In addition, the programme places GMT rules in a broader strategic context, discussing how global minimum taxation is reshaping tax competition, the design of tax incentives and qualified refundable tax credits (QRTCs), and how countries and businesses are adapting to these shifts. The implications for mergers and acquisitions are covered in detail, including the impact of Pillar Two on valuation, tax due diligence, deal structuring and post-acquisition integration, while the course also highlights emerging areas of tax risk, potential disputes and available dispute resolution mechanisms.
By the end of the Masterclass, participants will be able to confidently assess the impact of GMT rules on multinational groups, apply the GloBE rules to concrete scenarios, develop effective compliance strategies, navigate the post-GMT tax landscape, and anticipate risks and opportunities arising from this fundamental shift in global taxation.
- Scope of OECD GloBE rules
Impact assessment of GMT rules
- Application of IIR, QDMTT and UTPR
- Potential impact on international tax planning structures
- Implementation of the side-by-side arrangement
- Global developments on Pillar 2 implementation
Pillar 2 compliance
- Application of Transitional CbCR safe harbours
- Application of side-by-side safe harbour and UPE safe harbour
- Application of substance-based tax incentive safe harbour
- Application of simplified ETR safe harbour
- GloBE information returns and compliance obligations
Post Pillar 2 international tax landscape:
- Tax competition and tax incentives
- Mergers and acquisition and intragroup transfers
- Disputes and disputes management
After this masterclass, the participants will be able to:
- Apply the complex GloBE rules to specific examples, cases and real-life scenarios
- Assess the impact of various elements in the application of GloBE minimum taxes, e.g. IIR, UTPR and QDMTT, the order of their application and their application to common international tax planning structures – e.g. holding, financing, IP and supply chain structures
- Develop strategies to comply with GMT obligations around the globe after the implementation of the side-by-side package, including through the application of transitional and permanent safe harbours
- Identify the impact of QDMTT and navigate changes and strategies for dealing with tax competition and incentive regimes in the post-GMT era
- Evaluate the impact of GMT on M&A transactions and changes that need to be made in M&A due diligence
- Identify potential areas of disputes and dispute management options
- Shee Boon Law, IBFD, Independent Tax Consultant, the Netherlands
- Carlos Gutiérrez Puente, IBFD, Senior Principal Associate, the Netherlands
This is an intermediate-level masterclass and is intended for professionals who already have a basic understanding of the GloBE framework and are looking to deepen their expertise and apply it in practice. It is particularly relevant for in-house tax teams, tax advisors, policymakers and tax officials involved in implementing, administering or applying GMT rules.
The course is suitable for government staff, tax advisers, lawyers, accountants, in-house tax directors, controllers and finance staff.
The Masterclass will take place at a venue in Amsterdam — final location details will be confirmed soon.
This is an intermediate-level course. Participants taking this course will be expected to have an understanding of the basic concepts of the GloBE Rules. Those who do not meet this requirement are recommended to follow IBFD’s online Fundamentals on GloBE Rules – Pillar Two prior to joining this course. Alternatively, participants may wish to attend the Fundamentals course on GMT in Amsterdam, scheduled for 14-16 April 2026 prior to attending this intermediate level course.
No advance preparation is necessary. All required study material is provided during the training.
International Bureau of Fiscal Documentation (IBFD) is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have the final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National. Registry of CPE Sponsors through its website: www.nasbaregistry.org.
In accordance with the standards of the National Registry of CPE Sponsors, CPE credits have been granted based on a 50-minute hour. (National Registry of CPE Sponsors ID Number: 107989) Number of CPE credits: 18
In accordance with the standards of the IAB-IEC, CPE credits have been granted based on a full hour. (IAB-IEC recognition nr. B0181/2010-09) Number of CPE credits: 17
See our FAQ section for more information. Regarding administrative policies such as complaint, cancellation or refund, please refer to our Terms and Conditions or please contact us via email.
- Field of Study - Taxes
- Delivery format: Group Live
- Course level: Intermediate
IBFD reserves the right to cancel this Masterclass up to 14 days before the commencement date.
The programme and line-up of speakers are subject to change.
In the unfortunate event of the masterclass being cancelled, registered participants will receive a credit note by email at the email address provided and a full refund of the masterclass registration fee thereafter. In light of this, participants are kindly advised to make refundable travel and accommodation arrangements. Participants act at their own risk when booking non-refundable travel and accommodation arrangements. IBFD is not responsible for any loss incurred by participants who book non-refundable travel and accommodation arrangements.
All bookings related to travel and accommodation, as well as local transportation, visas, vaccinations and travel insurance are at the participant’s own cost. Registered participants will receive a list of hotels that offer corporate rates.
IBFD offers a group discount on this product. Eligibility is as follows:
For 5–9 registrations in a group, a 5% discount is automatically applied to the order.
For 10 or more registrations in a group, a 10% discount is automatically applied to the order.
