Pillar Two – Fundamentals and Practice

STI Taxand and WTL in collaboration with Queen Mary University of London (QMUL), is pleased to offer a comprehensive preparation course for the CIOT Pillar Two Award, to visit the CIOT website click here specifically designed for candidates sitting the June 2026 examination.

The course provides a structured, syllabus-driven and practice-oriented approach to the OECD Global Anti-Base Erosion (GloBE) Rules, equipping participants with the technical depth, computational skills and interpretative capability required to succeed in the Pillar Two Award and to apply Pillar Two rules confidently in real-world multinational contexts.

The programme reflects the full scope and weighting of the ADIT Pillar Two Award syllabus, combining academic rigour with the practical insights of leading international tax practitioners.

The course fully covers the ADIT Pillar Two Award Syllabus 2026, click here to download the syllabus including all examinable areas and relative weightings:

• Scope of the GloBE Rules
  • MNE groups, constituent entities, excluded entities.
  • Ultimate Parent Entities and consolidated revenue threshold
• Charging Provisions
  • Income Inclusion Rule (IIR)
  • Undertaxed Profits Rule (UTPR)
  • Ordering rules and allocation of top-up tax
• Computation of GloBE Income or Loss
  • Financial accounting starting point.
  • Adjustments, permanent establishments and flow-through entities
• Adjusted Covered Taxes
  • Definition and allocation of covered taxes
  • Temporary differences and post-filing adjustments
• Effective Tax Rate and Top-Up Tax
  • ETR calculation mechanics
  • Substance-based income exclusion
  • De minimis exclusion and QDMTT
• Corporate Restructurings and Holding Structures
  • Mergers, demergers, joint ventures and multi-parented groups
  • Distribution regimes and tax neutrality rules
• Administration, Safe Harbours and Transition Rules
  • Filing obligations and GloBE Information Return
  • Transitional CbCR safe harbours
  • Deferred tax adjustments and transitional reliefs
• Subject to Tax Rule (STTR)
• Inclusive Framework Policies and Governance

For more details about the syllabus please visit the CIOT website by clicking here.

By the end of the course, participants will be able to:

• Demonstrate detailed and advanced knowledge of the Pillar Two GloBE Rules across all syllabus areas.
• Apply Pillar Two rules in written and computational exam-style scenarios.
• Analyse complex fact patterns involving ETR calculations, top-up tax and allocation mechanisms.
• Identify and resolve issues arising from group restructurings, hybrid entities and transitional rules.

Confidently approach the CIOT Pillar Two Award examination with a structured exam strategy

The CIOT Pillar Two Award is a globally recognised specialist qualification that:

• Confirms technical mastery of the OECD Global Minimum Tax
• Signals advanced expertise to multinational enterprises, advisory firms and tax authorities.
• Is increasingly relevant as Pillar Two becomes fully operational across jurisdictions.

For professionals advising large groups, the Pillar Two Award has rapidly become a benchmark credential in international tax.

• Practitioner-led teaching by senior international tax specialists actively advising on Pillar Two implementation.
• Academic excellence through collaboration with QMUL, a leading institution in tax and international law
• Exam-focused methodology, aligned precisely with CIOT expectations and marking standards.
• Emphasis on practical application, not just technical description
• Global perspective reflecting real MNE structures and cross-border complexity.

This course bridges the gap between technical rules and practical execution.

This programme is designed for new and experienced international tax professionals alike:

• International tax advisers and lawyers
• In-house tax professionals of multinational groups
• International Tax & Transfer pricing and tax policy specialists
• Professionals preparing for the CIOT Pillar Two Award (June 2026)
• Individuals seeking deep technical competence in Pillar Two

No. As the Pillar Two Award is open to international tax professionals and students in countries around the world, from a range of professional and academic backgrounds, there are no prerequisite qualifications that you need to hold in order to be eligible.

However, we advise that the Pillar Two Award is roughly equivalent to approximately a Level 5 UK qualification (which broadly equates to the second year of a UK undergraduate degree).

The course qualifies for Continuing Professional Development (CPD) hours, subject to the rules of the participant’s professional body. A certificate of attendance will be provided.

Once you’ve successfully passed the Pillar Two Award exam, you will automatically receive from the CIOT your Pillar Two Award certificate in the post, free of charge.

Visit the CIOT website by clicking here.

Please contact this email address if interested:
[email protected]

Visit the CIOT website by clicking here

For the exams timetable click here

You can find below the most important information:

• Eligible Countries
• Syllabus Information
• Sample Exam
• Permitted Books