Global Minimum Tax and BEPS Implementation Course

Course Introduction

The global tax landscape is undergoing a profound transformation driven by the introduction of the Global Minimum Tax framework and the OECD Base Erosion and Profit Shifting (BEPS) initiative. These reforms aim to ensure that multinational enterprises pay a fair share of tax regardless of where they operate, thereby reducing aggressive tax planning, profit shifting, and jurisdictional arbitrage. This course provides a comprehensive understanding of these global tax reforms and their practical implementation across jurisdictions.

The program explores the policy foundations and technical architecture of the Global Minimum Tax, including Pillar Two rules, income inclusion rules, undertaxed payment rules, and global anti-base erosion mechanisms. Participants will gain clarity on how these frameworks interact with domestic tax systems and reshape international tax competitiveness, compliance obligations, and revenue allocation among countries.

A major focus of the course is the BEPS framework, which addresses tax avoidance strategies that exploit gaps and mismatches in tax rules. Participants will examine key BEPS actions such as transfer pricing reforms, treaty abuse prevention, hybrid mismatch arrangements, and country-by-country reporting requirements. These elements are essential for strengthening transparency and ensuring fair taxation of multinational enterprises.

The course also addresses the practical challenges faced by tax authorities and multinational corporations in implementing global tax reforms. These include data collection complexities, compliance burdens, system integration issues, and capacity constraints. Participants will learn how governments and organizations are adapting their tax infrastructure, reporting systems, and enforcement mechanisms to meet new international standards.

Digitalization plays a crucial role in the successful implementation of BEPS and global minimum tax rules. The course examines how technology-driven tax administration systems, automated reporting tools, and data analytics are being used to improve compliance monitoring, detect tax risks, and ensure accurate reporting of global income. This technological shift is central to modern tax governance.

By the end of the program, participants will be equipped with the technical, policy, and operational knowledge required to understand, implement, and manage global minimum tax and BEPS frameworks. The course prepares professionals to navigate international tax reforms confidently while ensuring compliance, reducing risks, and supporting fair global taxation systems.

Duration

5 days

Who Should Attend

• Tax policy makers and government officials
• International tax specialists and advisors
• Revenue authority officers and tax auditors
• Transfer pricing professionals
• Corporate tax managers and compliance officers
• Multinational enterprise finance executives
• Legal practitioners in international tax law
• Economic and fiscal policy analysts
• OECD and development agency consultants
• Accounting and auditing professionals

Course Objectives

• Equip participants with a comprehensive understanding of the Global Minimum Tax framework, including its structure, policy objectives, and implications for international taxation systems.
• Develop deep knowledge of OECD BEPS initiatives and their role in preventing tax avoidance, profit shifting, and erosion of national tax bases across jurisdictions.
• Enable participants to analyze the interaction between global tax rules and domestic tax systems, ensuring effective policy alignment and compliance readiness.
• Strengthen technical expertise in implementing Pillar Two rules, including income inclusion rules, undertaxed payment rules, and global anti-base erosion mechanisms.
• Build capacity to assess the impact of BEPS actions such as transfer pricing reforms, treaty abuse prevention, and hybrid mismatch arrangements on tax administration.
• Enhance skills in evaluating multinational corporate tax structures and identifying aggressive tax planning strategies used to shift profits across borders.
• Improve understanding of country-by-country reporting requirements and how they support transparency and risk assessment in global tax administration.
• Equip participants with practical tools to manage compliance challenges arising from global minimum tax implementation within complex organizational structures.
• Strengthen the ability to integrate digital tax systems, automated reporting tools, and data analytics into BEPS and global tax compliance frameworks.
• Prepare participants to support policy development, institutional reform, and international cooperation efforts aimed at ensuring fair and sustainable global taxation.

Course Outline

Module 1: Introduction to Global Tax Reform

• Understanding the evolution of international tax systems and the need for global coordination in taxation policies.
• Overview of global tax challenges including profit shifting, tax competition, and base erosion issues.
• Key principles underlying the Global Minimum Tax and OECD BEPS initiative.
• Role of international organizations in shaping global tax governance frameworks.

Module 2: Structure of the Global Minimum Tax

• Detailed analysis of Pillar Two rules and their policy objectives in global taxation systems.
• Understanding income inclusion rules and their application in multinational taxation structures.
• Overview of undertaxed payment rules and their role in preventing tax base erosion.
• Interaction between global minimum tax rules and domestic corporate tax systems.

Module 3: BEPS Framework and Action Plans

• Comprehensive review of OECD BEPS action plans and their implementation across jurisdictions.
• Addressing tax avoidance strategies through hybrid mismatch rules and treaty abuse prevention.
• Strengthening transfer pricing regulations to ensure fair allocation of taxable profits.
• Enhancing transparency through country-by-country reporting and disclosure requirements.

Module 4: Transfer Pricing and Profit Allocation

• Principles of arm’s length pricing and their role in international tax compliance.
• Identifying aggressive transfer pricing practices used to shift profits across jurisdictions.
• Documentation requirements and compliance standards for multinational enterprises.
• Dispute resolution mechanisms in transfer pricing audits and cross-border tax cases.

Module 5: Tax Transparency and Reporting Standards

• Understanding global standards for tax transparency and information exchange systems.
• Implementation of country-by-country reporting frameworks for multinational corporations.
• Role of tax authorities in analyzing global financial and tax data sets.
• Enhancing accountability through standardized tax disclosure requirements.

Module 6: Digital Tax Administration Systems

• Use of digital platforms to support global tax compliance and reporting processes.
• Application of automated data collection systems in international tax enforcement.
• Integration of artificial intelligence in identifying tax risks and anomalies.
• Enhancing efficiency through e-reporting and real-time tax monitoring systems.

Module 7: Compliance Challenges in Multinational Taxation

• Identifying key compliance challenges faced by multinational enterprises under BEPS rules.
• Managing cross-border tax obligations across multiple jurisdictions and regulatory systems.
• Addressing administrative burdens and system complexity in global tax compliance.
• Strategies for aligning internal tax processes with international tax requirements.

Module 8: Policy Implementation and Institutional Coordination

• Roles of governments in implementing global minimum tax and BEPS frameworks.
• Coordination between tax authorities, ministries of finance, and international bodies.
• Institutional capacity building for effective tax reform implementation.
• Managing policy transitions and regulatory alignment across jurisdictions.

Module 9: Risk Management and Enforcement

• Identifying high-risk tax structures and aggressive tax planning arrangements.
• Strengthening enforcement strategies for global tax compliance monitoring.
• Developing audit approaches for multinational enterprise tax structures.
• Enhancing cooperation in cross-border tax investigations and enforcement actions.

Module 10: Future of International Taxation

• Emerging trends in global tax governance and digital economy taxation.
• Impact of globalization, digitalization, and crypto-assets on tax systems.
• Evolution of international tax cooperation frameworks and agreements.
• Strategic outlook for sustainable and equitable global taxation systems

Training Approach

This course will be delivered by our skilled trainers who have vast knowledge and experience as expert professionals in the fields. The course is taught in English and through a mix of theory, practical activities, group discussion and case studies. Course manuals and additional training materials will be provided to the participants upon completion of the training.

Tailor-Made Course

This course can also be tailor-made to meet organization requirement. For further inquiries, please contact us on: Email: training@upskilldevelopment.com Tel: +254 721 331 808

Training Venue 

The training will be held at our Upskill Training Centre. We also offer training for a group (at a discount of 10% to 50%) at requested location all over the world. The Onsite course fee covers the course tuition, training materials, two break refreshments, buffet lunch, airport transfers, Upskill gift package, and guided tour.

Visa application, travel expenses, dinners, accommodation, insurance, and other personal expenses are catered by the participant

Certification

Participants will be issued with Upskill certificate upon completion of this course.

Airport Pickup and Accommodation

Airport pickup and accommodation is arranged upon request. For booking contact our Training Coordinator through Email: training@upskilldevelopment.com, +254 721 331 808

Terms of Payment:

Unless otherwise agreed between the two parties’ payment of the course fee should be done 3 working days before commencement of the training so as to enable us to prepare better.