Intensive Course: An Introduction to the OECD Global Minimum Tax (Pillar 2) Taxation

Taxation Law Research Programme (TLRP)

Intensive Course

An Introduction to the OECD Global Minimum Tax (Pillar 2) Taxation

Hear from an Italian legal practitioner and Professor of international tax law at the University of Milan Bicocca, Stefano Grilli, together with Belinda Law, barrister-at-law and fellow of the Taxation Institute of Hong Kong, who will provide you with a comprehensive introductory analysis of both the OECD-G20 Inclusive Framework Global Minimum Tax – Pillar 2 (GloBE) and the relevant legislation to be enacted in Hong Kong affecting MNE groups.

Topics covered will include the main aspects of the following GMT topics:

• The objective and subjective scope and main definitions of the OECD Model Rules.
• The charging provisions (Income Inclusion Rule (IIR) – Undertaxed Profits Rule (UTPR) and Qualified Domestic Minimum Top-up Tax (QDMTT)), their interaction and rule order.
• The computation of the GloBE Income or Loss.
• The computation of the Adjusted Covered Taxes.
• The computation of the Effective Tax Rate (ETR) and the relevant top-up tax.
• Analysis of some dedicated rules applying to specific entities.
• Rules applying in case of corporate reorganizations.
• The transition rules regarding the tax features of pre-GloBE tax periods entering into the GloBE financial years.
• Pillar 2 rules to be enacted under Hong Kong law: peculiarities of Hong Kong legislation.

Dates & Time:
Friday 20 June 2025 (6:30pm – 9:00pm, 2.5 hours)
Saturday 21 June 2025 (2:30pm – 5:00pm, 2.5 hours)
Sunday 22 June 2025 (11:00am – 5:00pm, 5 hours with 1 hour lunch)

Course Fee: HK$3,000.00 per person (Please mail a cheque payable to “The University of Hong Kong” to Flora Leung, Faculty of Law, The University of Hong Kong, 10/F Cheng Yu Tung Tower, Centennial Campus, Pokfulam Road, Hong Kong. Course Fee is non-refundable.)

Deadline for registration: 30 April 2025 (Wednesday)

Registration: please return the Registration Form to Flora Leung by email at aiiflhku@hku.hk

Flyer and registration form can be downloaded HERE.

Enquiries: Flora Leung at aiiflhku@hku.hk / 3917-2941