Pillar Two - Fundamentals and Practice

The course will take place once a week across seven weeks.

We follow the 6-step structure of GloBE in our teaching to ensure a comprehensive coverage of the rules.

The agenda is below:

Week One (Thursday 9 October)

• 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

Weeks Two and Three (Thursday 16 and 23 October)

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

Week Four (Thursday 30 October)

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

Week Five (Thursday 6 November)

• 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 Six (Thursday 13 November)

• 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 Seven (Thursday 20 November)

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

Christiana HJI Panayi

Christiana HJI Panayi is a Professor in Tax Law at Queen Mary University of London. She teaches on the EU Tax Law, International Tax Law and Transfer Pricing courses of the LLM Programme. Christiana is also a researcher at the Institute for Fiscal Studies and a visiting professor at the Vienna University of Economics and Business and the University of Notre Dame. In the past, Christiana was also an Adjunct Professor of European Union Tax Law at New York University, a Visiting Professor at Sorbonne University (Ecole de droit de la Sorbonne, Université Paris 1), at the University of Luxembourg and at the University of Lausanne. Christiana has published extensively in the area of EU and International Tax Law and is considered a leading expert in her field.

Christiana speaks regularly at tax conferences and teaches abroad. She has lectured at New York University, the University of Cambridge, Boston College, the University of Lausanne, the Chartered Institute of Taxation, the European Commission, the Academy of European Law, the Vienna University of Economics and Business Administration, the University of Luxembourg, the University of Amsterdam and various other universities. She has also designed and conducted workshops on International and EU tax law for Her Majesty’s Revenue and Customs, the UK Treasury and various south European organizations and accounting firms. In October 2024, Christiana testified as an expert at the FISC Committee of the European Parliament.

Christiana has been appointed twice as an expert member at the European Commission’s Joint Transfer Pricing Forum (JTPF) and the Platform for Tax Good Governance. She is also a member of the CFE’s ECJ Taskforce, a member of the BEPS Monitoring Group, a member of the European Association of Tax Law Professors and a member of the CIOT’s Examination Sub-Committee for the ADIT.

Christiana studied at Oxford University for her BA in Jurisprudence and for the BCL. She also has a PhD from the London School of Economics. Before joining Queen Mary, Christiana worked for Allen and Overy LLP. She is a non-practising solicitor of England and Wales.

Christos Theophilou, BSc (Econ.), FCA, ADIT, MSc Tax Law (Oxon), LLB Law (Hons)

Christos Theophilou is a distinguished tax expert, providing advisory services to both private and corporate clients on intricate international tax and transfer pricing issues. His expertise encompasses cross-border investments, private equity structuring, structured finance, intellectual property structuring, and international trade. Christos holds an MSc in Tax Law from Oxford University, a Bachelor's degree in Economics, and an LLB Law degree from Frederick University. He is a Chartered Accountant in England & Wales and has obtained the Advanced Diploma in International Taxation (ADIT) from the UK Chartered Institute of Taxation. Christos is a prolific contributor to various esteemed international tax publications, including IBFD, Tax Notes International, Bloomberg Tax, International Tax Review, Edward Elgar, and IFA. Furthermore, Christos is currently a member of the Τax Policy and Strategy committee of ICPAC. Christos also serves as a freelance lecturer for Tolley's (LexisNexis) and IBFD, where he lectures on ADIT Paper 1 Principles of International Tax, Transfer Pricing, and Pillar 2. He is a frequent speaker at international tax conferences, sharing his extensive knowledge and insights with the global tax community.

Costas Savva, International Tax Lawyer, LL.M (WU)

Costas Savva is a tax lawyer specializing in international tax law and Transfer Pricing, with extensive experience advising multinational enterprises on complex tax and cross-border matters. He provides strategic guidance on structuring global operations, optimizing cross-border transactions, and addressing challenges related to corporate tax compliance in multiple jurisdictions. Costas advises clients on tax treaty interpretation, corporate tax planning, and ensuring alignment with global tax reforms, such as OECD initiatives and EU directives. He also supports clients in designing and implementing effective Transfer Pricing policies, navigating their structures to ensure compliance with evolving global regulations and guidelines. Costas holds an LL.B. and a Master of Laws (LL.M.) in International Taxation from the Vienna University of Economics and Business (WU), establishing a strong academic foundation in global tax principles. As a qualified Fellow of the Association of Certified Chartered Accountants (ACCA), he seamlessly integrates legal and financial expertise to deliver tailored and practical solutions for his clients. In addition to his advisory work, Costas regularly publishes insightful articles on various tax topics, contributes to the advancement of the profession as a lecturer in ADIT courses, and serves as the Cypriot correspondent for the IBFD holding regime. He is also the co-author of the book Limiting Base Erosion, edited by Professor Michael Lang.

Demis Ioannou BA , FCA, MSc Tax Law (Oxon), LLB Law (Hons)

Demis Ioannou is both a qualified practicing lawyer and a UK Chartered Accountant, specializing in corporate income tax law, transfer pricing, and international tax (treaty) law. He has an remarkable track record, advising clients on complex corporate tax issues. His extensive interest in comparative income tax law across jurisdictions, including the US, UK, Canada, and Australia, provides him with a unique advantage in addressing intricate tax challenges. Demis began his career at a Big Four accounting firm before joining Taxand as a senior partner.

Demis holds the following degrees and professional qualifications: MSc in Taxation, University of Oxford (68%); LLB Law, University of Frederick, Cyprus (First Class); BA Accounting and Finance (First Class); Chartered Accountant (ICAEW), Professional Qualification; Passed the Cypriot Bar Exams.

Selected Publications: The Cyprus Equity Law Book – Demis contributed Chapter 6: The Taxation of Trusts and Chapter 8: The Taxation of Public Trusts; Studies in the History of Tax Law, Volume 10 – The Colonial Income Tax Model (1922) and the Lessons We Can Learn: Cyprus as a Specific Example, Cambridge; Guide to U.S. Transfer Pricing (LexisNexis) – Contributed the Cypriot chapter; Oxford thesis on the BEPS Project (67%), supervised by Dr Richard Collier.