Pillar Two – Fundamentals and Practice course with Queen Mary University of London

After eight insightful weeks, the Pillar Two – Fundamentals and Practice course that STI Taxand did in collaboration with Queen Mary University of London has officially come to a close!

We extend our heartfelt thanks to QMUL for this incredible opportunity and to all the dedicated professionals who participated. Your commitment to mastering international tax has made this program truly impactful.

Course Highlights

Participants mastered:

• The practical implications of Pillar Two top‑up taxes under the Qualified Domestic Minimum Top‑Up Tax (QDMTT), Income Inclusion Rule (IIR), and Undertaxed Profits Rule (UTPR)
• How these rules are expected to apply in real‑world scenarios
• Potential unexpected outcomes arising from the application of these global tax rules.

Each week’s topic was shared as below:

Week 1:

• Introduction
• Policies of the Inclusive Framework on Pillar Two Step 1 – Determine whether the MNE Group is within scope: Identify Groups within scope
• Step 2 –Allocate income of Constituent Entities on a Jurisdictional Basis: Identify the location of each Constituent Entity within the Group and allocate the income to these Constituent Entities

Week 2&3:

• Step 3 – Calculate the GloBE Income: Determine GloBE Income of each Constituent Entity

Week 4:

• Step 4 – Determine Adjusted Covered taxes: Determine taxes attributable to GloBE Income of a Constituent Entity

Week 5:

• Step 5 – Compute the Effective Tax Rate and calculate the Top-up Tax: Calculate the Effective Tax Rate for all Constituent Entities located in the same jurisdiction and determine resulting Top-up Tax

Week 6:

• Step 6 – Charge the Top-up Tax under QDMTT, IIR or UTPR: Impose Top-up Tax under QDMTT, IIR or UTPR in accordance with agreed rule order and allocation mechanisms

Week 7:

• Guest lecture on “Can Side by Side Work? by Professor Reuven Avi-Yonah

Week 8:

• Advanced Topics & Revision & the future of tax incentives in the Pillar Two environment

Special Thanks to Our Team that helped to organise this course:

• Christos A. Theophilou
• Mr. Shee Boon Law
• Vasiliki Koukoulioti
• Deus Mugabe
• Coordinated by Christiana HJI Panayi

And a special mention to Professor Reuven Avi-Yonah for his insightful guest lecture on “Can Side by Side Work?” on 20 November 2025.

What’s Next?
Stay tuned for the new Pillar Two Award, with registrations opening on 6 January 2026!

🔗 Learn more about the programme here

Thank you for everyone that was part of this learning journey. We look forward to welcoming you again next year for another round of insightful sessions!