International Tax and Transfer Pricing (BEPS Pillar Two) Corporate Training
Build BEPS Pillar Two readiness for your group with hands-on labs on GloBE rules, transfer pricing, and control frameworks.
Edstellar, a corporate training company, delivers corporate training that helps your team learn to master the BEPS Pillar Two global minimum tax rules and international transfer pricing. Your employees compute effective tax rates, apply the IIR, UTPR, and QDMTT mechanics, align transfer pricing policies with GloBE outcomes, and build audit-ready control frameworks with confidence.
Instructor-led group trainingVirtual / on-site / off-site10 languagesDelivered inEnglish, Spanish, Mandarin, German, Arabic, Portuguese, Hindi, French, Japanese, Italian100+ countriesWe have delivered inUnited States, United Kingdom, India, Canada, Germany, France, Netherlands, UAE, Saudi Arabia, Singapore, Australia, Japan, Brazil, South Africa and 90+ more countries
How we build an audit-ready pillar two team
The Edstellar PILLAR TWO Capability Model
Diagnose your exposure
We map your in-scope entities, jurisdictional footprint, and current data readiness to focus the program.
Standardize the mechanics
Your team aligns on GloBE calculations, ETR logic, and the IIR, UTPR, and QDMTT order of application.
Practice in labs
Guided labs work ETR computations, safe harbour checks, and GloBE data mapping on realistic entity structures.
Measure the skill
Assessments check calculation accuracy and documentation quality, showing skill gains for each cohort.
Scale the capability
Repeatable calculation templates and control checklists carry your Pillar Two workflow into daily tax operations.
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Program Overview: What is International Tax and Transfer Pricing (BEPS Pillar Two) Corporate Training?
International Tax & Transfer Pricing (BEPS Pillar Two) is a 25-hour instructor-led program for tax and finance leaders facing the global minimum tax. It covers international tax foundations and BEPS Pillar Two, GloBE mechanics with IIR, UTPR and QDMTT, effective tax rate computation, transfer pricing, and reporting operations. Participants complete a Pillar Two readiness assessment.
Training runs as 25 hours of instructor-led sessions built around real calculations. Participants compute effective tax rates, apply safe harbours, work through GloBE mechanics scenarios, and redesign transfer pricing policies for the new rules. Instructors with international tax experience review every calculation and coach participants on data readiness and defending positions. The program closes with the Pillar Two Readiness Assessment capstone, where each team assesses a simulated multinational.
Pillar Two changed the game: a 15% global minimum tax with complex mechanics and real penalties for getting it wrong. Tax teams that rely on old playbooks face top-up taxes and restatements. This program builds the technical command to get Pillar Two right the first time.
The Pillar Two Readiness Assessment capstone asks each team to act as advisors to a simulated multinational: mapping entities, computing effective tax rates, testing safe harbours, identifying top-up tax exposure, and delivering a readiness report with a remediation roadmap, all challenged by instructors who probe the calculations. The report teams defend is structured like one a board would actually receive. Tax leaders return with a methodology they can apply to their own group immediately, which is the whole point of the exercise.
Through hands-on sessions, employees compute jurisdictional effective tax rates, test safe harbour positions, align transfer pricing documentation with Pillar Two data, and build control frameworks for ongoing compliance. The result is a workforce that keeps your group audit-ready as minimum tax rules roll out worldwide.
What's Included in this Workshop for Your Enterprise Teams
- 1
Pillar Two foundations
Understand the GloBE rules and the 15 percent minimum tax.
- 2
GloBE mechanics
Apply IIR, UTPR, and QDMTT in calculation labs.
- 3
ETR and safe harbours
Compute effective tax rates and test safe harbour positions.
- 4
Transfer pricing alignment
Link TP policies and documentation to GloBE outcomes.
- 5
Capstone readiness assessment
Deliver a Pillar Two readiness roadmap for review.
- Hybrid delivery: live virtual sessions and onsite workshops
- Flexible scheduling across time zones for global teams
- Dedicated training advisor from scoping to completion
- Digital course materials and calculation workbooks
- Completion certificates for participants
- Post-training support for your tax team
Build your team's skills. Anywhere in the world.
Real-world use cases
from day one
Instructor-led training
for your teams
Delivered globally
in 100+ countries
Enterprise Training Solutions Customized for Your Company
One partner for instructor-led corporate training, delivered the way your teams work.
Request a Training Quote- Customized Training Delivery
- Scale Your Training: Small to Large Teams
- In-person Onsite, Live Virtual or Hybrid Training Modes
- Plan from 2000+ Industry-ready Training Programs
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International Tax and Transfer Pricing (BEPS Pillar Two) Course Topics and Program Outline
A tailored 25-hour, six-module workshop: one learning journey from international tax foundations to a capstone Pillar Two readiness assessment. Sessions pair concepts with hands-on labs on GloBE mechanics, ETR computation, and transfer pricing alignment, using your team's own tools and templates.
Built by Edstellar with international tax practitioners
Built by practitioners who model GloBE exposure and defend transfer pricing positions in production, shaped around your stack and use cases.
Skill checks map your team's international tax knowledge, GloBE data readiness, and Pillar Two exposure before training begins.
Live instruction covers BEPS Pillar Two foundations and the IIR, UTPR, and QDMTT mechanics in focused learn sessions.
Guided labs work ETR computations, safe harbour checks, and TP alignment across 8 hours of supervised practice.
Your team builds reporting workflows and completes a capstone readiness assessment in 10.5 hours, reviewed against audit standards.
From Pillar Two foundations to a capstone readiness assessment, every technique is practiced in guided labs.
Delivered as
Delivered as a hybrid program of live instruction and guided labs, scheduled around your team's calendar in flexible batches.
Map a sample group's entities to Pillar Two scope and adoption status.
learna)Residence, source, and double taxation: the core architecture
b)The OECD BEPS project and the road to Pillar Two
c)GloBE rules at a glance: scope, the 15 percent minimum rate, and the EUR 750 million threshold
d)Pillar Two adoption status and what it means for your group
Trace a low-taxed constituent entity through IIR, UTPR, and QDMTT outcomes.
learna)The Income Inclusion Rule (IIR): top-up tax at the parent level
b)The Undertaxed Profits Rule (UTPR): the backstop mechanism
c)Qualified Domestic Minimum Top-Up Taxes (QDMTTs)
d)Rule order, exclusions, and de minimis carve-outs
Compute a jurisdictional ETR and run a safe harbour check on sample data.
practicea)GloBE income: building the denominator from financial accounts
b)Adjusted covered taxes: building the numerator
c)Jurisdictional blending and ETR calculation step by step
d)Substance-based income exclusion (SBIE) mechanics
e)Transitional and permanent safe harbours in practice
Align a sample TP policy with GloBE outcomes in a documentation drill.
practicea)How Pillar Two interacts with the arm's length principle
b)DEMPE analysis and profit methods under minimum-tax scrutiny
c)Aligning TP policies with GloBE outcomes and substance
d)Documentation touchpoints: master file, local file, and CbCR
e)Common TP risk patterns that trigger top-up tax exposure
Map sample ERP data to GloBE calculation inputs and filing fields.
applya)The GloBE Information Return: data requirements and filing
b)Building the Pillar Two data model from ERP and provision data
c)Financial statement and tax provision impacts
d)Registrations, deadlines, and penalty exposure
e)Designing a repeatable quarterly compliance routine
Deliver an end-to-end Pillar Two readiness assessment for review.
applya)Scoping a readiness assessment across jurisdictions and entities
b)Modeling ETR and top-up tax exposure under safe harbours
c)Designing the control framework: roles, reviews, and audit trails
d)Presenting findings and the readiness roadmap
e)Instructor review and improvement plan
Customize this program tailored to your team?
Tell us your training needs: what your team already works with, the level they’re at, and the topics you want them to focus on. We’ll adjust the modules, duration and hands-on labs, and send you a customized outline for your group.
Key Skills and Outcomes Your Team Will Gain
Practical skills your team applies from day one: computing ETRs, applying GloBE mechanics, aligning transfer pricing, and running Pillar Two compliance.
Apply the GloBE rules in scope checks
Explain the 15 percent minimum rate and which entities fall in Pillar Two scope.
Charge top-up tax through IIR and UTPR
Trace top-up tax through the IIR, UTPR, and QDMTT in the correct order of application.
Compute jurisdictional effective tax rates
Build GloBE income and adjusted covered taxes into defensible ETR calculations.
Use transitional and permanent safe harbours
Test safe harbour positions to focus compliance effort where it matters most.
Align transfer pricing with GloBE outcomes
Keep TP methods, DEMPE analysis, and documentation consistent with minimum tax results.
Run Pillar Two reporting operations
Map ERP data to GloBE calculations and prepare the information return with an audit trail.
Design minimum tax control frameworks
Set up roles, reviews, and evidence routines that keep compliance audit-ready.
Teams that Benefit from this International Tax and Transfer Pricing (BEPS Pillar Two) Group Training
Built for tax, finance, audit, and legal groups preparing for global minimum tax rules across jurisdictions. Content adapts to role and experience, so each cohort practices the workflows it owns.
Minimum tax mechanics your tax team can defend
Core tax owners learn GloBE mechanics, ETR computation, and documentation that holds up under authority review, built around their entity structures.
Workflow friction
- Top-up tax rules applied inconsistently across regions
- ETR models without documented assumptions
- Pillar Two gaps found only after filings are due
How the program helps
- Consistent IIR and UTPR application across entities
- ETR calculations with documented steps
- GloBE documentation ready for authority review
Practice use cases
- IIR and UTPR labs
- ETR computation drills
- Safe harbour checks
- Documentation practice
Provisioning that reflects minimum tax exposure
Finance teams learn how Pillar Two flows into provisions, deferred tax positions, and disclosures, and how to keep data audit-ready.
Workflow friction
- Provision estimates disconnected from GloBE models
- Deferred tax impacts assessed too late
- Quarter-end pressure with filings pending
How the program helps
- Top-up tax exposure reflected correctly in provisions
- Disclosure inputs tied to GloBE calculations
- Clean handoffs between finance and tax
Practice use cases
- Provision workshops
- Data mapping labs
- Disclosure checklists
Controls that keep Pillar Two compliance audit-ready
Audit and risk teams build testing checklists and control frameworks that catch GloBE data gaps before authorities do.
Workflow friction
- Pillar Two controls tested only after issues surface
- No standard evidence for ETR assumptions
- Audit findings repeating across jurisdictions
How the program helps
- Repeatable Pillar Two control testing routines
- Early-warning indicators for ETR drift
- Evidence trails that support audit defense
Practice use cases
- Control testing labs
- Evidence reviews
- Readiness walkthroughs
Entity structures that match your tax positions
Legal and compliance teams align entity structures, registrations, and filing obligations with the group's Pillar Two strategy.
Workflow friction
- Entity records that contradict GloBE filings
- Missed registrations in adopting jurisdictions
- Filing positions set under time pressure
How the program helps
- Entity data consistent with GloBE filings
- Registration and filing obligations tracked
- Compliance strategy planned before deadlines
Practice use cases
- Entity reviews
- Filing walkthroughs
- Deadline planning
Cohorts train as a cross-functional workforce, with each group aligned on shared calculation and documentation standards.
Prerequisites: This program benefits tax, finance, audit, and legal professionals who work with multinational groups and cross-border transactions. Familiarity with corporate tax basics helps but is not required; concepts are built from the ground up. No prior Pillar Two experience is needed, and each cohort's labs adapt to its entity structures, tools, and industry context.
Tax Analyst to Pillar Two Specialist
Tracks how tax and finance professionals progress from international tax fundamentals to advanced minimum tax compliance across the program's learn, practice, and apply phases.
A program that grows with tax careers, from international tax basics to confident Pillar Two compliance.
Mixed cohort, or several teams at once?
We can tailor the training to different teams, roles, and experience levels within the same program.
Certificate of Training Completion.
On successful completion, employees receive an Edstellar course completion certificate, recognizing their commitment to ongoing learning and professional development. It validates the skills they have built and motivates them to keep growing and contribute to organizational success.
Earned, not attended. Awarded on completion of all hands-on labs and the capstone project.
Training Delivery Modes: Virtual, Onsite and Hybrid
Hybrid-first delivery with live instruction and guided labs, in the format that suits your teams. Sessions can run onsite, live virtual, or as a hybrid mix.
Hybrid Training
Live instructor-led sessions blend onsite workshops with virtual labs, so distributed tax teams learn together without travel overhead.
- Instructor-led sessions across onsite and virtual
- Guided labs on GloBE calculations and documentation
- Flexible scheduling across time zones
- One cohort, shared templates and checklists
Onsite Training
An instructor delivers the full program at your office, working your team's entity structures and calculation models in the room.
- Full program delivered at your office
- Labs built around your entity data
- Direct Q&A with a tax practitioner
- Team-wide alignment in one location
Live Virtual Training
Live virtual sessions over Zoom or Teams with the same guided labs and calculation practice, supported by shared lab guides and LMS materials.
- Live virtual sessions on Zoom or Teams
- Guided labs with screen-share reviews
- Digital materials and lab workbooks
- Recordings for post-session review
Need a training format that works for your team?
Full days, half days across weeks, or split by module. Tell us the delivery window and we schedule the cohort around it.
Frequently Asked Questions
Share your team size and training goals through the request form. We respond with a tailored training plan and a quote for your cohort.
Yes. A short discovery call helps us understand your entity footprint, team roles, and timelines before we scope the program.
Yes. The program runs live virtual over Zoom or Teams with guided labs, or as a hybrid mix with onsite workshops.
Yes. An instructor can deliver the full program at your office, working your team's entity structures and data in the room.
The program runs 25 hours across six modules, typically scheduled in flexible batches around your team's calendar.
Question not answered here?
Put it in the request. A training specialist answers it directly, within one business day.
Where this Training Fits in Your Team's learning path.
International tax and Pillar Two come once your team handles domestic accounting and statutory filings with confidence, because group-wide calculations start from accurate entity numbers. After the international layer, the path closes with tax audit readiness, so the positions your team takes on transfer pricing and minimum tax can be defended.
Why Choose Edstellar as Your International Tax and Transfer Pricing (BEPS Pillar Two) Corporate Training Provider
Edstellar is a corporate training company with 5,000+ certified trainers and 2,000+ courses, delivering tailored programs for enterprise teams worldwide.
EXPERT TRAINERS
YEARS DELIVERING
ORGANIZATIONS TRAINED
CERTIFIED
Tailored
Every cohort trains on its own entity structures and calculation templates, so labs mirror the jurisdictions your team manages.
Proven Methodology
A structured learn, practice, and apply flow moves your team from GloBE basics to a capstone readiness assessment and review.
Practice-Based Learning
Guided labs cover ETR computation, safe harbour checks, and GloBE data mapping on realistic multinational entity structures.
Expert Trainers
Sessions are led by international tax practitioners who model GloBE exposure and support minimum tax compliance for global groups.
Global Scale
Hybrid delivery across time zones lets distributed tax, finance, and audit teams train together without travel overhead.
Measurable Outcomes
Assessments on calculation accuracy and documentation quality show skill gains before your team files its first GloBE return.
Build Pillar Two Readiness Through Traceable Calculations and Data Decisions
Edstellar connects international tax concepts with practical Pillar Two analysis using a simulated multinational. Participants examine scope, trace GloBE mechanisms, calculate jurisdictional effective tax rates, and map reporting inputs. The readiness assessment brings transfer pricing, documentation, and controls together, with review of assumptions, calculation evidence, and jurisdiction-specific questions requiring further examination.
- Step 01
Consult
We assess corporate tax familiarity, multinational entity structures, and responsibilities for provisions, transfer pricing, or reporting to identify gaps in Pillar Two analysis and data readiness.
- Step 02
Plan
We establish scope and jurisdictional context before IIR, UTPR, and QDMTT mechanics, then connect ETR calculations, safe-harbour analysis, and reporting inputs in the readiness assessment.
- Step 03
Align
We align international tax expertise with tax, finance, audit, and legal roles, establishing explicit case assumptions about adoption status and the entity structure being examined.
- Step 04
Customize
We adapt simulated group structures, transfer-pricing policies, and ERP extracts to familiar business models, retaining documented assumptions for jurisdictional calculations and safe-harbour checks.
- Step 05
Execute
Participants calculate ETRs, trace top-up tax outcomes, and map data to reporting fields, receiving feedback on computational consistency, policy documentation, and gaps in supporting evidence.
- Step 06
Evaluate
We assess the readiness report for traceable inputs, justified scope decisions, consistent GloBE calculations, documented safe-harbour reasoning, and clearly assigned data and control gaps.
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→OD consulting
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→Managed training services
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→Coaching solutions
Executive and manager coaching that keeps skills in use.
Start an RFP shaped to your needs.
Answer three quick questions about team size, scope, and how often you need the program run, then send the request from the last step. Everything you choose travels with it, so you only fill this in once.
How many team members need training?
International Tax & Transfer Pricing (BEPS Pillar Two) Training Packages & Pricing
Where L&D holds an annual budget, license packages price the whole year at once instead of raising a purchase order per workshop. Hours and licenses are pooled across teams, programs and locations, so unused capacity is not stranded in one department.
Starter
120
trainee licenses64 hours of group training
Tailored for SMBs
Growth
320
trainee licenses160 hours of group training
Ideal for growing SMBs
Enterprise
800
trainee licenses400 hours of group training
Designed for large corporations
Custom
Unlimited
trainee licensesDuration set by the rollout
Multi-region and multi-year
Training Packages & Pricing
Choose the training format that works for your team. Pricing is customized based on your requirements, cohort size, and delivery needs.
Request International Tax and Transfer Pricing (BEPS Pillar Two) Training for Your Team
Tell us your team size, entity footprint, and timelines to receive a tailored training plan and quote. Book a discovery call to discuss your goals; we confirm availability and respond with a proposal.