International tax planning has become one of the most sought-after competencies in law. From the launch of the BEPS project in 2013 to the entry into force of the global minimum tax (Pillar Two) in 2024–2026, the rules of the game have changed dramatically. Today, more than 140 countries in the OECD Inclusive Framework are implementing unified standards to combat base erosion, and the European Union has mandated companies to report cross-border arrangements through DAC6. For a lawyer, accountant, or CFO, this means only one thing: old optimization methods no longer work, and ignorance of modern rules can cost clients millions.
Why International Tax Planning Has Become Critical
The global tax reform launched by the OECD and G20 has brought about two key components—Pillar One and Pillar Two. Pillar Two sets a minimum effective corporate tax rate of 15% for multinational groups with revenue exceeding €750 million. This is no longer a recommendation but a mandatory rule implemented in the legislation of EU countries since 2024. In addition, other mechanisms are actively applied:
- BEPS Action Plan — 15 measures against aggressive tax planning, including tackling hybrid mismatches, artificial profit shifting, and abuse of tax treaties.
- CRS (Common Reporting Standard) — automatic exchange of financial information between tax authorities worldwide. Offshore accounts are no longer a secret.
- DAC6 — an EU directive requiring intermediaries (lawyers, accountants, consultants) to report cross-border arrangements that may be considered aggressive.
- CFC Rules (Controlled Foreign Companies) — control over profits of subsidiaries in low-tax jurisdictions, in force in almost all developed countries, including the US, Russia, and EU states.
According to the OECD, by 2025 more than 140 jurisdictions have already implemented BEPS standards, and this number continues to grow. In such conditions, every cross-border transaction requires careful analysis. That is why the labor market has seen a sharp increase in demand for professionals who not only know national tax law but also understand international rules and can apply them in practice.
What You Will Learn in the Course 'International Tax Planning (OECD, IRS, EU)'
This course on the ASI Biont platform is a unique opportunity to systematize knowledge in global taxation. The program covers all key aspects that every practicing tax lawyer or consultant needs today.
BEPS: 15 Actions That Change the World
You will examine in detail each of the 15 action points of the BEPS Action Plan, from taxing the digital economy to anti-transparency measures. You will learn how these rules transform tax systems across countries and how to avoid risks when structuring international operations.
Transfer Pricing: Defense in Disputes
Transfer pricing is one of the most complex areas where tax authorities most often make additional assessments. You will master pricing methods (tNMM, CUP, cost plus, or resale minus), learn to prepare documentation according to OECD TPG standards, and defend your position in courts and during audits.
Tax Treaties and Permanent Establishments
Understanding double tax agreements (DTAs) is an essential skill for any international practitioner. You will learn how to properly determine a permanent establishment, apply limitation of benefits provisions, and plan cross-border dividends, interest, and royalties.
CFC Rules: Control of Subsidiary Structures
Controlled foreign company rules have become significantly stricter in many countries. The course will teach you to assess CFC risks when setting up holding structures and to use exemptions and immunities provided by legislation.
CRS and DAC6: Error-Free Reporting
You will understand how automatic exchange of information (CRS) works and how to comply with DAC6 requirements. You will analyze typical mistakes that lead to fines and learn to correctly classify arrangements for timely reporting.
Pillar One and Pillar Two: Global Minimum Tax
A separate module is dedicated to the new rules on allocating taxing rights and the global minimum tax. You will learn to calculate the effective rate for a group of companies, apply the Income Inclusion Rule (IIR), and determine exclusions.
What Skills You Will Gain
After completing the course, you will be able to:
| Skill | Application in Work |
|---|---|
| Analysis of tax structures | Identifying risks before tax authorities do |
| Structuring transactions | Using DTA, BEPS, and CFC rules in compliance with the law |
| Preparation of transfer pricing documentation | Defense in litigation and tax audits |
| Calculation of global minimum tax | Correct application of Pillar Two for international groups |
| Managing DAC6 and CRS reporting | Compliance with US, EU, and other countries' regulatory requirements |
These skills not only increase your value in the labor market but also significantly boost income. According to recruiting portals, international tax lawyers in large companies and law firms earn 30–50% more than their colleagues who work only with national law.
How Learning Works on asibiont.com
One of the main reasons we chose the ASI Biont platform is its unique AI-based learning system. You don't learn through fixed video lessons or watch boring lectures. Instead, a neural network generates personalized text lessons tailored to your skill level, goals, and learning pace.
AI Generation of Personalized Lessons
The first step is a short diagnostic of your knowledge and preferences. Based on this data, the AI creates an individualized curriculum. If you are new to international taxation, the AI starts with basic concepts and gradually leads you to complex topics such as the income inclusion mechanism in Pillar Two. If you are already an experienced professional, the program adapts to fill specific gaps.
Text Format and 24/7 Access
Learning takes place entirely in text format. This is a huge advantage for busy professionals:
- you can study at any time—day or night, from a laptop or smartphone;
- text is always more convenient for analysis than video: you can return to complex wording, copy fragments into notes;
- the neural network explains complex concepts in plain language, with examples, analogies, and practical tasks.
AI learning is not just a trend. Research in educational technology shows that personalized programs significantly improve material retention compared to traditional courses. Each lesson is designed with the student’s specific tasks and mistakes in mind, saving up to 40% of time.
Who This Course Is For
The course 'International Tax Planning (OECD, IRS, EU)' will be useful for:
- tax lawyers and attorneys who want to expand their practice to international matters;
- accountants and auditors working with multinational clients;
- CFOs and tax managers of companies operating in multiple jurisdictions;
- compliance specialists responsible for reporting and adherence to regulatory requirements;
- master's students and graduates planning a career in international taxation.
This course does not require deep knowledge of tax law, but a basic understanding of financial reporting will be an advantage. The main focus is on practical aspects: you will analyze real cases and typical mistakes encountered when structuring transactions.
Let's Look at a Typical Case
Imagine a lawyer advising a client—an international IT company from Europe. The client wants to move profits to a low-tax jurisdiction to save on taxes. The old scheme no longer works: CFC rules and CRS allow tax authorities to see all accounts and controlled foreign companies. Without knowledge of the new requirements, the lawyer might propose a scheme that leads to accusations of tax fraud.
After completing the course, this lawyer will be able to properly assess risks, propose an alternative structure taking into account Pillar Two, prepare transfer pricing documentation, and notify about the transaction in advance through DAC6. As a result, the client legally saves $1.2 million—that’s how much additional assessments could amount to with the wrong approach. This is not an isolated case. Such problems are now solved by specialists who master modern international tax planning tools.
Conclusion
The world of taxation has changed. BEPS, Pillar Two, CRS, and DAC6 rules are not temporary measures but a new reality. You have a choice: ignore these changes and lose clients, or master current competencies and become one of the most sought-after specialists in your field.
The course 'International Tax Planning (OECD, IRS, EU)' on the ASI Biont platform provides exactly the knowledge and skills that define a career in modern law. You will gain a systematic understanding of OECD, IRS, and EU rules, learn to apply them in real transactions, and protect yourself from reputational risks. And thanks to AI learning, the process will be fast, convenient, and individual.
Start today—go to the course page and take the first step toward a new level of professionalism: International Tax Planning (OECD, IRS, EU).
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