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Arinjay Kumar Jain

Learn about the proposed Global Minimum Corporate Tax  . This course covers international developments  on Global Minimum Tax.

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Learn about the proposed Global Minimum Corporate Tax  . This course covers international developments  on Global Minimum Tax.

The Course is a Basic level course on concept of Global Minimum Tax. It covers the topics relating to Meaning of Global Minimum Tax, Concept of Global Minimum Tax, Developments  on GMT in international front, Journey So Far, Objectives of Global Minimum Tax and  Scope Of Application of Global Minimum Tax, Global Minimum Tax - Objective, Pillar 2 – Scope Of Application, Key Rules under the Global Minimum Tax, Typical MNE Group Structure, Pillar 2 - Key Rules For GMT Application, Pillar 2 – Meaning Of Key Rules, Pillar 2 – Meaning Of Key Rules, Income Inclusion Rule  - IIR of Global Minimum Tax, Income Inclusion Rule - Top-Down Approach -  Global Minimum Tax, Switch Over-Rule  - Global Minimum Tax, Under Taxed Payment Rule And Exceptions, IIR Vs UTPR, Example On Global Minimum Tax, Assumptions For Various Examples, Global Minimum Tax Example 1 – UPE Has Implemented LIR, Global Minimum Tax Example 2 – UPE Has Not Implemented LIR, Global Minimum Tax Example 3 – Comprehensive Example 1, Global Minimum Tax Example 4 – Comprehensive Example 2, Global Minimum Tax Example 5, Impact On Low-Tax Countries And Their Response, How May Countries With Low/ No Tax Respond

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What's inside

Learning objectives

  • Understand the concept of global minimum corporate tax  ;
  • Understand rules to compute global minimum corporate tax
  • Examples on global minimum corporate tax
  • How global minimum corporate tax will impact countries with low tax rate .
  • Income inclusion rule, subject to tax rule, top up tax concept

Syllabus

Introduction
What is Global Minimum Corporate Tax ?
International Developments on Global Minimum Corporate Tax
Objectives of Global Minimum Tax and Scope Of Application of Global Minimum Ta
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Key Rules under the Global Minimum Corporate Tax
Income Inclusion Rule - IIR of Global Minimum Tax
Income Inclusion Rule - Top-Down Approach
Switch Over-Rule - Global Minimum Tax
Under Taxed Payment Rule - Global Minimum Tax
Income Inclusion Rule Vs Under Taxed Payment Rule
Example On Global Minimum Tax and Assumptions
Example 1 – UPE Has Implemented IIR
Example 2 – UPE Has Not Implemented IIR
Example 3 – Comprehensive Example 1
Example 4 – Comprehensive Example 2
Example 5 - Comprehensive Example 23
Impact of Global Minimum Tax on Low-Tax Countries

Good to know

Know what's good
, what to watch for
, and possible dealbreakers
Explores the Income Inclusion Rule (IIR) and Under Taxed Payment Rule (UTPR), which are critical for understanding the mechanics of the global minimum tax
Covers the objectives and scope of application of the Global Minimum Tax, providing a foundational understanding of its purpose and reach
Includes examples of Global Minimum Tax calculations under various scenarios, such as when the Ultimate Parent Entity (UPE) has or has not implemented the IIR
Examines the potential impact on low-tax countries and their possible responses, offering insights into the broader economic and policy implications
Focuses on international developments related to the Global Minimum Tax, which is subject to change and may require learners to stay up-to-date with current events

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Activities

Be better prepared before your course. Deepen your understanding during and after it. Supplement your coursework and achieve mastery of the topics covered in Global Minimum Tax with these activities:
Review International Tax Principles
Strengthen your understanding of international tax principles to better grasp the complexities of the Global Minimum Tax.
Browse courses on Transfer Pricing
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  • Review key concepts in international tax law.
  • Study transfer pricing methodologies.
  • Familiarize yourself with BEPS action items.
Read 'International Taxation in a Nutshell'
Gain a solid foundation in international taxation to better understand the context and implications of the Global Minimum Tax.
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  • Obtain a copy of 'International Taxation in a Nutshell'.
  • Read the chapters on tax treaties and transfer pricing.
  • Take notes on key concepts and definitions.
Compile a Glossary of Global Minimum Tax Terms
Solidify your understanding of key terms and concepts related to the Global Minimum Tax by creating a comprehensive glossary.
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  • Identify key terms from the course materials.
  • Research and define each term clearly and concisely.
  • Organize the terms alphabetically for easy reference.
Four other activities
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Practice Calculating the Effective Tax Rate
Sharpen your skills in calculating the effective tax rate, a crucial component in understanding the impact of the Global Minimum Tax.
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  • Find sample financial statements of multinational enterprises.
  • Calculate the effective tax rate using different scenarios.
  • Compare your results with published data and benchmarks.
Write a Blog Post on the Impact of GMT on Low-Tax Jurisdictions
Deepen your understanding of the Global Minimum Tax by researching and writing about its potential impact on low-tax jurisdictions.
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  • Research the economic structure of low-tax countries.
  • Analyze the potential effects of the Global Minimum Tax.
  • Write a blog post summarizing your findings and insights.
Read 'Pillar Two Blueprints'
Gain a comprehensive understanding of the technical details of the Global Minimum Tax by studying the OECD's Pillar Two Blueprints.
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  • Download the Pillar Two Blueprints from the OECD website.
  • Carefully read the sections on the IIR and UTPR.
  • Take detailed notes on the key provisions and examples.
Model the Impact of GMT on a Multinational Enterprise
Apply your knowledge of the Global Minimum Tax by creating a financial model to simulate its impact on a multinational enterprise.
Show steps
  • Select a multinational enterprise with operations in multiple jurisdictions.
  • Gather financial data and information on its tax structure.
  • Build a financial model to simulate the impact of the Global Minimum Tax.
  • Analyze the results and draw conclusions about the potential impact.

Career center

Learners who complete Global Minimum Tax will develop knowledge and skills that may be useful to these careers:
Government Revenue Agent
Government revenue agents work for tax authorities, such as the Internal Revenue Service, conducting audits and investigations to ensure compliance with tax laws. They may specialize in a particular area of taxation, such as individual income tax or corporate tax. This course helps those wanting this role by offering an intricate understanding of global minimum tax, helpful when investigating international tax evasion schemes. The course examples help in recognizing violations.
Tax Analyst
Tax analysts interpret and apply tax laws to specific situations, conducting research, preparing reports, and assisting with tax audits. They may specialize in a particular area of taxation, such as international tax or corporate tax. This course helps those wanting to be tax analysts by offering specific knowledge on one of the most important developments in international tax. Those who wish to become tax analysts would benefit from the detailed examples concerning the implementation of the income inclusion rule.
Tax Consultant
Tax consultants provide tax advice to individuals and businesses, helping them minimize their tax liabilities and comply with tax laws. They may specialize in a particular area of taxation, such as individual income tax, corporate tax, or international tax. This course helps those wanting to be tax consultants by providing insights on navigating through global minimum tax. The course modules will help in understanding the implications for multinational enterprises.
Tax Accountant
A tax accountant prepares and files tax returns for individuals or businesses, ensuring compliance with all applicable tax laws and regulations. This work often involves analyzing financial records, identifying potential deductions and credits, and providing guidance on tax planning strategies. This course helps those wanting to be tax accountants by providing a solid understanding of the global minimum tax, especially its calculation and impact, helping in international tax compliance. The course's examples would be relevant for understanding real-world tax scenarios.
Tax Partner
Tax partners are leaders within public accounting firms who specialize in taxation. They provide tax advice to clients, manage tax engagements, and develop new business opportunities. Tax partners need to have a deep understanding of international tax issues, including the global minimum tax, to effectively advise their clients. The course's focus on real-world examples of the global minimum tax is valuable for tax partners.
Tax Director
Tax directors are senior leaders responsible for setting the overall tax strategy for an organization. They oversee all aspects of tax compliance, planning, and controversy, and work closely with other departments to ensure tax considerations are integrated into business decisions. An understanding of the global minimum tax is critical for tax directors in multinational companies. The course's coverage of income inclusion rules and under-taxed payment rules provides valuable insights.
Tax Manager
Tax managers oversee the tax function within an organization, managing tax compliance, planning, and risk management activities. This includes ensuring the accuracy and timeliness of tax filings, advising on tax implications of business decisions, and leading tax audits. This course is relevant for tax managers who need to stay abreast of the latest developments in global tax policy. The course's discussion of low-tax countries and their response to the global minimum tax is valuable for tax managers.
Transfer Pricing Specialist
Transfer pricing specialists analyze and document the pricing of transactions between related entities within a multinational enterprise, ensuring compliance with transfer pricing regulations. They also assist with transfer pricing audits and defend transfer pricing policies. This course may be useful for transfer pricing specialists. It covers the global minimum tax and its potential implications for transfer pricing practices. The course modules on key rules would apply directly to this career.
International Tax Lawyer
International tax lawyers advise multinational corporations and individuals on cross-border tax issues, including transfer pricing, tax treaties, and foreign tax credits. This work is a critical component of global business operations. This course may be useful to lawyers specializing in international tax law, the global minimum tax being one of the most important concepts in the field of international tax. Learning about the objectives and scope of application helps build a foundation in this area.
Compliance Officer
Compliance officers ensure that an organization adheres to laws, regulations, and internal policies. They develop and implement compliance programs, conduct risk assessments, and investigate potential compliance violations. This course helps compliance officers by going over some of the most important rules currently being put into place. The course modules on the income inclusion rule and switch over rule help those wanting to be compliance officers.
Economic Policy Analyst
Economic policy analysts research and evaluate the economic effects of government policies, providing recommendations to policymakers. They may specialize in tax policy, international trade, or other areas. This course may be useful to economic policy analysts focusing on international tax competitiveness. The course goes over the tax implications of government policy and helps further understanding of this important topic.
Financial Controller
Financial controllers are responsible for overseeing the accounting and financial reporting functions within an organization. This includes ensuring the accuracy and integrity of financial statements, managing the month-end and year-end close processes, and developing internal controls. This course may be useful for financial controllers who need to understand the tax implications of their company's global operations. The course's discussion of the scope of the global minimum tax helps build a foundation.
Financial Planner
Financial planners help individuals and families achieve their financial goals by providing advice on investments, retirement planning, insurance, and other financial matters. They develop personalized financial plans based on their clients' needs and objectives. This course may be useful for financial planners advising clients with international investments or business interests. The course's discussion of the impact on low-tax countries is a valuable introduction.
Chief Financial Officer
A Chief Financial Officer oversees all financial activities of a company, including budgeting, forecasting, and financial reporting. They provide strategic financial leadership and ensure the company's financial health. A CFO may find the lessons in this course to be useful. This course's coverage of the global minimum corporate tax, including its objectives, scope, and key rules helps provide an informative background.
Business Development Manager
Business development managers identify and pursue new business opportunities for an organization. They develop and implement business development strategies, build relationships with potential clients, and negotiate deals. This course may be useful for business development managers in companies operating in international markets. The course describes how to implement some of the most relevant guidance on a global scale.

Reading list

We've selected two books that we think will supplement your learning. Use these to develop background knowledge, enrich your coursework, and gain a deeper understanding of the topics covered in Global Minimum Tax.
This OECD publication provides a detailed explanation of the Pillar Two rules, which form the basis of the Global Minimum Tax. It covers the Income Inclusion Rule (IIR) and the Undertaxed Payments Rule (UTPR) in detail. is essential for understanding the technical aspects of the Global Minimum Tax. It valuable reference tool for anyone working in international tax.
Provides a concise overview of international taxation principles, making it an excellent resource for understanding the foundational concepts behind the Global Minimum Tax. It covers topics such as transfer pricing, tax treaties, and cross-border transactions. While not specifically focused on the Global Minimum Tax, it provides essential background knowledge. This book is commonly used as a reference text in international tax courses.

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