Navigating GloBE Rules (Pillar Two): Key Implications and Practical Considerations (Live Webinar)


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Date:
24 July 2026, Friday

Time:
03.00 - 05.00PM
Venue:
Online Classroom in or outside of Singapore

Details/ Promotion:
Please click here for more details and to register. 
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Contact:
Please refer to organiser’s webpage here.
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Programme Synopsis

With the implementation of OECD Pillar Two – Global Anti-Base Erosion (GloBE) Rules and Singapore’s adoption of the global minimum tax regime from 2025, multinational groups in Singapore face significant changes in their tax landscape.

This course by ISCA provides practical insights into the application of the GloBE Rules, focusing on both Singapore HQ groups as well as in-scope MNE groups having a presence in Singapore. Through real-world examples and case studies, participants will gain a clear understanding of compliance requirements, tax exposure, and strategic considerations in adapting to the evolving international tax framework.

Programme Outline

A Highlight of Key Areas:
Introduction to Pillar Two – GloBE Rules
  • Background and objectives of OECD BEPS 2.0 initiative
  • Overview of GloBE Rules – Income Inclusion Rule (IIR), Undertaxed Profits Rule (UTPR), and Qualified Domestic Minimum Top-up Tax (QDMTT)
  • Scope and applicability – threshold requirements (EUR 750 million consolidated revenue)
  • Key definitions and concepts (covered taxes, GloBE income, jurisdictional blending)

Computation of Effective Tax Rate and Top-Up Tax
  • Step-by-step approach to ETR computation under GloBE
  • Broad overview of top-up tax computation and allocation mechanisms
  • Substance-based income exclusion rules
  • Safe harbour provisions (transitional CbCR safe harbour)
  • Exercise: Computation of ETR and top-up tax for a sample Singapore-headquartered group

Singapore Implementation and Implications for HQ Groups
  • Overview of Singapore’s adoption of Pillar Two (from 2025)
  • Interaction with Singapore’s existing tax incentives and regimes
  • Impact on effective tax rates of Singapore entities
  • Considerations for Singapore HQ groups with overseas subsidiaries
  • Discussion: Practical challenges faced by Singapore-based MNCs

Global Implementation and Compliance Requirements
  • Overview of global implementation status, local compliance requirements
  • Interaction between IIR, UTPR, and QDMTT across jurisdictions
  • GloBE Information Return – key components and timelines
  • Penalties and risks of non-compliance
  • Coordination between group entities across jurisdictions; data and reporting challenges
  • Exercise: Identifying data gaps and compliance roadmap

Strategic Considerations and Tax Planning in a Pillar Two Environment
  • Reassessment of group structures and holding arrangements
  • Review of intercompany transactions and financing structures
  • Managing impact on tax incentives and substance requirements
  • Alignment with broader business and operational strategies
  • Discussion: Sample Case Study on Tax Optimisation in a Pillar Two Environment

About the Presenter(s)/ Trainer(s)


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Mr Dilpreet Singh Obhan
Tax Partner
Dhruva Advisors, Singapore
Accredited Tax Advisor (Income Tax)


Dilpreet is a Tax Partner at Dhruva Advisors, based in Singapore, with over 20 years of extensive experience in tax compliance and consulting for both local and multinational companies. He is a member of the Institute of Chartered Accountants of India (ICAI), an associate member of the Institute of Singapore Chartered Accountants (ISCA), and an Accredited Tax Advisor with the Singapore Chartered Tax Professionals (SCTP).

Dilpreet specializes in a broad range of areas including tax-effective structuring for acquisitions and disposals, tax due diligence, post-acquisition structuring, inbound and outbound investments, and international tax advisory. His expertise also covers tax-efficient supply chain planning, group reorganizations, withholding tax matters, and the negotiation and application of tax incentives with government agencies.

He has advised clients across diverse sectors such as funds, consumer and retail, healthcare, life sciences, education, telecommunications, e-commerce, logistics, transportation, services, construction, and manufacturing.

A regular speaker at taxation seminars and workshops, Dilpreet has also served as a lecturer for the Tax Programme at the Tax Academy of Singapore. Prior to joining Dhruva, he held senior roles at leading global accounting firms including KPMG, Ernst & Young, and Arthur Andersen.

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Mr Aditya Hans
Partner
Dhruva Advisors, India


Aditya Hans is a Partner in Dhruva Advisors. Prior to this, he was a Partner in KPMG and has worked in competing firms like PwC & EY over his 20 years of consulting career. He is a Fellow Member of the Institute of Chartered Accountants of India.

He has expertise in international / cross-border tax structuring including, BEPS 2.0 (Pillar One and Two), Transfer Pricing (TP audit defense and litigation, APA, MAP), Supply Chain Optimisation (tax), Permanent Establishment (PE) attribution, inbound & outbound entry/exit & profit /cash repatriation strategies for Indian and overseas jurisdictions.

He also has substantial experience in handling succession planning assignments, having worked closely with numerous Indian families to structure family offices, family charters/ constitutions, family settlements, business and non-business trusts, and successors/ beneficiaries being non-residents.

His expertise also includes advising listed and unlisted clients on a wide range of transactions, including tax due diligence, strategic advice to buy-side on acquisition structuring (also acquiring companies referred to NCLT under IBC proceedings), strategic advice to sell side for sell-off/hive-offs, business consolidations (i.e. reorganisation of group structure/ promoter family shareholding), demergers, spin offs, conversion to corporate entities, cash repatriation, Joint Ventures, and Private Equity fund raises. He also has extensive experience advising clients on fund structures, exchange control regulations, non-banking regulations and GIFT city. His deep tax and regulatory knowledge, coupled with strong financial and commercial acumen, adds significant value to any transaction.

His profile of clients include one of India’s largest homegrown Steel Manufacturer, Automobile Manufacturer, Pharmaceutical Company, Beverages Company, FMCG company and Unicorn in the technology and e-commerce space. He is a frequent speaker at technical forums on taxation and regularly contributes articles to Indian and International Tax Journals.

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Mr Ashish Jain
Associate Partner
Dhruva Advisors, India


Ashish Jain is an Associate Partner in the Firm and carries more than a decade of experience in international tax and transfer pricing.

He has hands-on work experience on compliance documentation, litigation support and business restructuring for inbound and outbound assignments, International Tax and Transfer Pricing planning projects for mid-scale and large-scale conglomerates from diversified industries. He has been involved in advising clients in optimising effective tax rate through supply chain optimisation and within the parameters of prevailing anti-abuse provisions.

He has also assisted in APA for certainty in transfer pricing policy and audit scrutiny. He has also handled the requirement of preparing Country-by-Country reporting (CBCR) and Masterfile under BEPS Action 13 for some of India’s leading MNC groups.

He has undertaken extensive research on arm’s length pricing for transactions involving inter-company financing (including loans, preference shares, guarantees, etc.) and intra-group services and has penned articles published in Indian and International Tax Journals.

Currently, he has been involved in advising clients for impact assessment under Pillar Two-GloBE Rules and advising clients on the impact of Pillar Two taxes assisting them with the necessary compliance requirement.








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