Pillar Two – Fundamentals and Practice

The Centre for Commercial Law Studies, Queen Mary University of London, is pleased to offer a new Executive Education course on the fundamentals and practice of Pillar Two.

Starting in 2024, countries are adopting the OECD Pillar Two proposals to safeguard their tax revenues from other nations imposing additional taxes on the profits of multinational groups operating within their borders. This evolving situation is expected to raise numerous practical questions for both multinational groups facing potential top-up taxes and the countries implementing these taxes.

This 7-week tax programme delves into the practical implications of Pillar Two top-up taxes that may be imposed under the QDMTT, IIR, and UTPR. We will examine how these rules are anticipated to apply and highlight some of the unexpected outcomes that may result from their application. The course is taught by prominent experts in the field and is an absolutely essential course for those wishing to master the rules and use them in their tax planning.

The programme is designed for practitioners, inhouse tax or finance directors, tax officials, accountants, lawyers, advisors, academics and university graduates in International Tax Law and other relevant disciplines, looking to navigate the complexity of the OECD Pillar Two rules.

No prior experience or knowledge of Pillar One and Two is required and no advance preparation is necessary.

The course will take place online on the following dates:

• Thursday 9 October, 2pm-5pm BST
• Thursday 16 October, 2pm-5pm BST
• Thursday 23 October, 2pm-5pm BST
• Thursday 30 October, 2pm-5pm GMT
• Thursday 6 November, 2pm-5pm GMT
• Thursday 13 November, 2pm-5pm GMT
• Thursday 20 November, 2pm-5pm GMT

A certificate of completion will be provided to participants upon conclusion of the course.

We are pleased to offer a 10% discount for QMUL alumni.

A group discount of 20% is available to organisations registering 3 or more people. Please get in touch for further information.

Christos Theophilou, BSc (Econ.), FCA, ADIT, MSc Tax Law (Oxon), LLB Law (Hons)

Partner | STI Taxand

Christos Theophilou is a distinguished tax expert, providing advisory services to both private and corporate clients on intricate international tax and transfer pricing issues. His expertise encompasses cross-border investments, private equity structuring, structured finance, intellectual property structuring, and international trade. Christos holds an MSc in Tax Law from Oxford University, a Bachelor's degree in Economics, and an LLB Law degree from Frederick University. He is a Chartered Accountant in England & Wales and has obtained the Advanced Diploma in International Taxation (ADIT) from the UK Chartered Institute of Taxation. Christos is a prolific contributor to various esteemed international tax publications, including IBFD, Tax Notes International, Bloomberg Tax, International Tax Review, Edward Elgar, and IFA. Furthermore, Christos is currently a member of the Τax Policy and Strategy committee of ICPAC. Christos also serves as a freelance lecturer for Tolley's (LexisNexis) and IBFD, where he lectures on ADIT Paper 1 Principles of International Tax, Transfer Pricing, and Pillar 2. He is a frequent speaker at international tax conferences, sharing his extensive knowledge and insights with the global tax community.

Costas Savva, International Tax Lawyer, LL.M (WU)

Partner | STI Taxand

Costas is a tax lawyer specializing in international tax law and Transfer Pricing, with extensive experience advising multinational enterprises on complex tax and cross-border matters. He provides strategic guidance on structuring global operations, optimizing cross-border transactions, and addressing challenges related to corporate tax compliance in multiple jurisdictions. Costas advises clients on tax treaty interpretation, corporate tax planning, and ensuring alignment with global tax reforms, such as OECD initiatives and EU directives. He also supports clients in designing and implementing effective Transfer Pricing policies, navigating their structures to ensure compliance with evolving global regulations and guidelines. Costas holds an LL.B. and a Master of Laws (LL.M.) in International Taxation from the Vienna University of Economics and Business (WU), establishing a strong academic foundation in global tax principles. As a qualified Fellow of the Association of Certified Chartered Accountants (ACCA), he seamlessly integrates legal and financial expertise to deliver tailored and practical solutions for his clients. In addition to his advisory work, Costas regularly publishes insightful articles on various tax topics, contributes to the advancement of the profession as a lecturer in ADIT courses, and serves as the Cypriot correspondent for the IBFD holding regime. He is also the co-author of the book Limiting Base Erosion, edited by Professor Michael Lang.

Demis Ioannou BA , FCA, MSc Tax Law (Oxon), LLB Law (Hons)

Partner | STI Taxand

Demis is both a qualified practicing lawyer and a UK Chartered Accountant, specializing in corporate income tax law, transfer pricing, and international tax (treaty) law. He has an remarkable track record, advising clients on complex corporate tax issues. His extensive interest in comparative income tax law across jurisdictions, including the US, UK, Canada, and Australia, provides him with a unique advantage in addressing intricate tax challenges. Demis began his career at a Big Four accounting firm before joining Taxand as a senior partner.

Demis holds the following degrees and professional qualifications: MSc in Taxation, University of Oxford (68%); LLB Law, University of Frederick, Cyprus (First Class); BA Accounting and Finance (First Class); Chartered Accountant (ICAEW), Professional Qualification; Passed the Cypriot Bar Exams.

Selected Publications: The Cyprus Equity Law Book – Demis contributed Chapter 6: The Taxation of Trusts and Chapter 8: The Taxation of Public Trusts; Studies in the History of Tax Law, Volume 10 – The Colonial Income Tax Model (1922) and the Lessons We Can Learn: Cyprus as a Specific Example, Cambridge; Guide to U.S. Transfer Pricing (LexisNexis) – Contributed the Cypriot chapter; Oxford thesis on the BEPS Project (67%), supervised by Dr Richard Collier.