Pillar Two requires Multinational Enterprises (“MNEs”) with €750 million or more in annual revenue to pay a global minimum tax of 15% on income earned in each country of operation. Following the successful completion of previous academies and bootcamps, we are launching the M&A Bootcamp. The academy consists of five 2-hour sessions/trainings.
The bootcamp will be a unique, all-encompassing interactive training on M&A issues in a Pillar 2 context to prepare you for change.
It aims at providing the foundation in understanding and dealing with complex issues on Pillar 2. This will be achieved by bringing together thought leaders and SMEs with different backgrounds (academic, policy, accounting and client facing).
Deloitte’s Pillar Two Mergers & Acquisitions Bootcamp
Importance and consideration of tax issues in M&A transactions in general
Consideration of P2 in M&A context
Key differences between P2 taxes and traditional income taxes
Impact of M&A on scoping
Definition of mergers& acquisitions and impact on consolidated revenue threshold test (Art. 1.1 and Art. 6.1.1 MR)
Case studies
Session 2 - 28 August
Broad topic
Details
Equity deals
Treatment of share deals under the GloBE/QDMTT Rules
Implications at the level of the seller, purchaser, and target (in particular Art. 3.2.1(c) and Art. 4.1.3(a) MR)
Commencement of target’s liability/IFRS 3 (Art. 6.2 MR)
Transaction before transition year (Aet. 9.1.1 MR)
Interaction with UAE CT
Case studies
Session 3 - 2 September
Broad topic
Details
Assets deals and GloBE reorg
Treatment of share deals under the GloBE/QDMTT Rules
Implications at the level of the seller, purchaser, and target (in particular Art. 6.3.1)
Transaction before transition year (Aet. 9.1.1 MR)
Interaction with UAE CT
Case studies
Session 4 - 4 September
Broad topic
Details
Due diligence, purchase price negotiations, deal structuring and the drafting of the transaction document
P2 in due diligence process (DD) process – Approach to DD
Contractual protection against P2 risks
Practical experience
Draft wordings
Locked Box vs Completion Accounts
P2 efficient structuring
Session 5 - 9 September (Hybrid)
Broad topic
Details
Recap JV structures and structuring Fund structing and flow-through entities
Treatmeent of JVs under GloBE/QDMTT
Various scenarios in terms of charging provisions and case studies (50% + control; 49% + no control; 49% + control)
Impact of M&A on CbCR safe harbor
Fees and cancellation:
The cost of attendance is USD850 per person (+ VAT). The indicated price includes participation in all session and access to training materials. An invoice will be issued before the workshop and our finance team will be in touch.
Organizers:
Jan Roderick van Abbe | Partner, International and M&A Tax | Middle East
Prof. Dr. Vikram Chand | Professor of Law, Tax Policy Center| University of Lausanne
