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International taxes

Expert commentary and practical guidance from ICAEW related to international taxation regimes.

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Library & Information Services

Tax by country or territory

A summary of resources available online and in print for taxation across the world, including double tax treaties and local tax guides.
Find a guide
A summary of resources available online and in print for taxation across the world, including double tax treaties and local tax guides.

BEPS

Expert commentary and practical guidance from ICAEW related to base erosion and profit shifting, commonly known as BEPS, within international taxation.
HMRC helps businesses prepare for Pillar 2
  • Article
  • 22 Jul 2024
In its third Pillar 2 update, HMRC explains aspects of the rules and sets out its plans for the coming months, including the release of the next stage of its Pillar 2 online service.
HMRC explains pillar two tax registration in the UK
  • Article
  • 03 Jun 2024
Groups within the scope of pillar two must register with HMRC within six months after the end of the first accounting period to begin on or after 31 December 2023.
Tax news in brief 17 January 2024
  • Article
  • 16 Jan 2024
Highlights from the broader tax news for the week ending 17 January 2024, including: more on the Customs Declaration Service; an update for insolvency practitioners on the VAT deregistration process; a reminder for taxpayers to use the HMRC app to find employment information; and the publication of further pillar two guidance.
Multilateral convention brings pillar one another step closer to implementation
  • Article
  • 12 Oct 2023
If ratified by at least 30 jurisdictions, the convention will introduce a new mechanism for allocating taxing rights to market jurisdictions.
Exclusive TAXguide 06/23: A basic guide to pillar two
  • Technical release
  • 04 Sep 2023
Pillar two is part of a package of initiatives agreed at OECD level by territories worldwide to tackle the challenges of taxing multinational enterprises (MNEs) cross-border. In the UK, it will be known as the multinational top-up tax and domestic top-up tax that will apply for accounting periods beginning on or after 31 December 2023.
Exclusive Implementation of OECD pillar two in the UK
  • Article
  • 04 May 2022
Richard Jones, Business Tax Manager of the ICAEW Tax Faculty, provides a high-level explanation of the proposed rules.
Tax news in brief
  • Article
  • 08 Sep 2021
Highlights from the broader tax news week ending 8 September, which includes: date confirmed for Autumn Budget; Scottish Government consults on tax policy; Eclipse Film Partnership members given six months to settle; FTT needs more resource to tackle delays; MTD regulations laid before parliament; new member for OECD BEPS framework and CTF reminder for teenagers.
Exclusive Analysing the OECD’s plan for international tax reform
  • Article
  • 01 Sep 2021
Lindsey Wicks and Wendy Nicholls discuss the issues surrounding BEPS 2.0, the OECD’s two-pillar approach to global tax reform

Digitalisation of tax: international perspectives

Find out how digital technology has been utilised by international tax administrators to reduce costs and improve compliance and tax yields, while crucially assessing the future challenges these economies face. The report includes:

  • 10 case studies from around the world
  • The benefits of pre-populating tax returns
  • The importance of data analytics
Find out more Download the report
Digitalisation of tax report cover

Double tax agreements

Explore practical resources from the Bloomsbury Accounting and Tax Service on double tax relief and international tax planning, as well as links to free online rates and summaries.

The ICAEW Library can also provide tax treaties from around the world using IBFD, a specialist cross-border tax research platform, along with materials that can help you to interpret and apply them. Available to ICAEW members and ACA students. Contact us at library@icaew.com or telephone +44 (0)20 7920 8620.

Double tax agreements Expert commentary and practical guidance from ICAEW on issues related to double taxation and the use of tax treaties in international taxation
Finding double tax treaties
  • Research guide
There are thousands of double tax treaties world-wide. The UK has double tax treaties with more than 130 countries, making it one of the world's largest networks. The library team can help you find the treaties you need.

FATCA and CRS

Practical guidance related to the Foreign Account Tax Compliance Act (FATCA) and the Common Standard on Reporting and Due Diligence for Financial Account Information (CRS).
TAXguide 12/17: CRS - notifying clients
  • Technical release
  • 30 Jun 2017
An explanation of the legal requirement for financial institutions and professionals to write to clients to whom they have given advice on offshore matters. The guide outlines the rules, suggests how you might comply and provides a draft client letter. Tax Faculty members can download the full guide.
Exclusive TAXguide 12/17: Common reporting standard: requirement to notify clients
  • Technical release
  • 30 Jun 2017
  • PDF (1,119kb)
In TAXguide 12/17 the Tax Faculty explains the new legal requirement for financial institutions and professionals, including tax advisers, to write to clients to whom they have given advice on offshore matters. The legal requirement to notify clients does not apply to all advisers nor to all clients. The guide outlines the rules and suggests how you might comply.
Exclusive Engagement letters helpsheet part 2 F
  • Helpsheets and support
  • 17 Aug 2016
  • DOCX (236kb)
Supplementary schedule to the main engagement letter helpsheet. Provides sample wordings to help you draft engagement letters. Covers Part 2 F - Trusts and estates tax returns.
Exclusive Engagement letters helpsheet
  • Helpsheets and support
  • 01 Jul 2016
  • DOCX (248kb)
Technical helpsheet providing sample wordings to help you draft engagement letters for a variety of typical engagements for both corporate and non-corporate clients. Includes full text and supplementary schedules.
What help is available from ICAEW for my tax query?
  • Helpsheets and support
  • 25 Jan 2016
List of resources available to help you with questions on tax.
FATCA: STEP guidance
  • Helpsheets and support
  • 15 Sep 2014
  • PDF (342kb)
The Model 1 Intergovernmental Agreement (IGA) is a standard template that facilitates FATCA reporting.
FATCA: STEP flowchart
  • Helpsheets and support
  • 01 Sep 2014
  • PDF (146kb)
Flowchart prepared by the Society of Trust and Estate Practitioners to illustrate trusts under a model 1 intergovernmental agreement (IGA): Jurisdiction X.
HMRC FATCA guidance
  • Helpsheets and support
  • 24 Aug 2014
  • PDF (1,044kb)
HMRC guidance notes on implementation of the International Tax Compliance (United States of America) Regulations 2014. These guidance notes supersede the 28 February 2014 version. Further amendments and additions to this guidance will be required as a result of the changes to the US Regulations.

Mandatory disclosure rules and DAC 6

Practical guidance and support on tax disclosure around the world, including the UK's Mandatory Disclosure Rules and DAC 6.

EU Council reaches agreement on exchange of information for crypto assets and advance tax rulings for high-net-worth individuals
  • Article
  • 26 May 2023
The unanimous agreement paves the way for greater co-operation between member states to reduce opportunities for tax avoidance and tax fraud using crypto assets, by amending the directive on administrative co-operation in the area of taxation (DAC).
Tax news in brief 19 April 2023
  • Article
  • 19 Apr 2023
Highlights from the broader tax news for the week ending 19 April 2023, including: closure of online VAT return; PAYE direct debits; TRS reporting requirements; interest rate increase for discounted gift trusts; NMW campaign; Finance Bill amendment for R&D; closure of the DAC6 reporting service; and Tax Administration and Maintenance Day.
Tax news in brief 8 February 2023
  • Article
  • 07 Feb 2023
Highlights from the broader tax news for the week ending 8 February 2023
Mandatory disclosure rules replace DAC 6 in the UK
  • Article
  • 24 Jan 2023
Cross-border tax avoidance arrangement disclosure rules devised by the OECD (known as the mandatory disclosure rules, or MDR) will enter into force in the UK on 28 March 2023. Arrangements entered into on or after this date must be reported to HMRC under this regime.
MDR: ICAEW concerned over backdated reporting
  • Article
  • 09 Feb 2022
ICAEW’s Tax Faculty welcomes that the new rules designed to implement the OECD’s model mandatory disclosure regime are targeted at those arrangements that might allow or facilitate tax evasion. However, it has concerns over the backdated reporting requirements, which exceed those of the predecessor DAC 6 legislation.
HMRC expands reporting portal for mandatory disclosure rules
  • Article
  • 16 Mar 2021
It is now possible to manually report arrangements between the UK and EU member states under the mandatory disclosure reporting regime (commonly known as DAC 6).
DAC6 the OECD Mandatory Disclosure Regimes in brief
  • Webinar
  • 15 Feb 2021
An introduction to DAC6 and the OECD Mandatory Disclosure Regimes in the context of UK reporting.
Final call for first UK DAC 6 reporting deadline
  • Article
  • 27 Jan 2021
27 January 2021: The first reports under the UK’s mandatory disclosure regime, based on the EU’s DAC 6, are due on 30 January 2021. ICAEW’s Tax Faculty provides a reminder of the rules.

Residence and domicile

Support from ICAEW on residence and domicile in the UK personal tax regime, including offshore investments.
Jon Moulton on the first Labour Budget
  • Article
  • 10 Dec 2024
The Labour government’s first Budget presents challenges for private equity, but nothing is insurmountable, says Jon Moulton CBE.
Budget updates on manifesto commitments
  • Article
  • 30 Oct 2024
The government has provided updates on some of the key measures included in the Labour Party’s general election manifesto, including the taxation of “non-doms” and charging VAT on services provided by private schools.
Residence and domicile: Taxpayer’s appeal on residency status dismissed
  • Helpsheets and support
  • 04 Oct 2024
The Upper Tribunal (UT) has found that the decision made by the First-tier Tribunal (FTT) in relation to a taxpayer’s residency status should be upheld...
Exclusive Practical points: personal tax October 2024
  • Helpsheets and support
  • 03 Oct 2024
Every month, the Tax Faculty publishes short, practical pieces of guidance to help agents and practitioners in their day-to-day work. This month covers property tax; and residence and domicile.
Exclusive Cryptoassets: international tax issues
  • Article
  • 03 Oct 2024
In the second of a series of articles on cryptoassets, members of ICAEW’s digital assets working party explain the key international tax considerations for individuals holding cryptoassets and for cryptoasset businesses.
Non-doms asked to check 2022/23 tax returns
  • Article
  • 30 Sep 2024
HMRC is asking individuals who are not UK-domiciled (non-doms) and are long-term UK residents to check if they should have paid the remittance basis charge for 2022/23.
Economy explainers: what is the non-dom regime?
  • Article
  • 12 Sep 2024
The Labour government has pledged to deliver on the previous administration’s commitment to abolish the tax rules for non-UK domiciled individuals. ICAEW experts explain what makes someone a non-dom, and why it matters.
Exclusive Practical points: personal tax July 2024
  • Helpsheets and support
  • 03 Jul 2024
Every month, the Tax Faculty publishes short, practical pieces of guidance to help agents and practitioners in their day-to-day work. This month covers: Property tax; and Residence and domicile.

Transfer pricing

Expert commentary and practical guidance from ICAEW related to transfer pricing in international taxation.

Tax news in brief 25 September 2024
  • Article
  • 25 Sep 2024
Highlights from the broader tax news for the week ending 25 September 2024, including: new guidance from HMRC on transfer pricing and VAT compliance; updated HMRC bank details for some taxes and duties; and a reminder from HMRC to register for self assessment by 5 October 2024.
UK international tax reform on the horizon?
  • Article
  • 23 Jan 2024
There is broad support for measures to reform the transfer pricing, permanent establishment and diverted profits tax rules.
DPT, transfer pricing and permanent establishment reforms: ICAEW responds
  • Article
  • 22 Aug 2023
ICAEW’s Tax Faculty welcomed HMRC proposals to make the UK legislation more closely aligned with OECD principles, but noted that there were good reasons to not fully adopt the OECD’s 2017 changes to the permanent establishment definition.
Tax news in brief 26 July 2023
  • Article
  • 25 Jul 2023
Highlights from the broader tax news for the week ending 26 July 2023, including: corporation tax filing for companies in insolvency; relief for foreign taxes in PAYE codes; HMRC guidance on negative earnings; and transfer pricing records regulations.
UK international tax legislation to be reformed
  • Article
  • 29 Jun 2023
The UK government is seeking views on reforming the UK rules on transfer pricing, permanent establishments, and diverted profits tax.
Draft Finance Bill 2022-23: enactment of OECD rules into UK law
  • Article
  • 22 Jul 2022
The draft legislation, announced on 20 July, includes the introduction of a top-up tax applicable to multinational business alongside changes to the UK transfer pricing documentation requirements.
The impact of work-from-anywhere policies
  • Article
  • 29 Jul 2021
What effect does a globally mobile workforce have on transfer pricing arrangements?
Transfer pricing documentation requirements to be made more robust
  • Article
  • 24 Mar 2021
Tougher requirements for transfer pricing documentation will better focus compliance interventions and bring more alignment with international approaches, according to HMRC. ICAEW’s Tax Faculty outlines a new consultation on updating rules.

Bloomsbury Accounting and Tax Service

Eligible firms have free access to Bloomsbury Professional's comprehensive online library, comprising around 80 titles from some of the country's leading tax and accounting subject matter experts. Find out who is eligible and how you can access the Accounting and Tax Service.

Exclusive Residence and domicile
  • eBook chapter
  • 2024
  • Nigel Eastaway, Jacquelyn Kimber, Ian Richards
  • Tax Advisers Guide to Trusts
Guidance for tax advisers on residence and domicile issues relevant to the taxation of trusts.
Exclusive International succession laws
  • eBook
  • 2024
  • Mark Bridges, David Way
  • International Succession Laws
Practical A-Z looseleaf providing information on international legal, tax and succession systems by country.
Exclusive Domicile
  • eBook chapter
  • 2024
  • Chris Erwood, Stephen Howe, Mark McLaughlin, Iris Wünschmann-Lyall
  • Inheritance Tax
Practical overview of the implications of a person’s domicile status for inheritance tax (IHT) purposes. Covers ‘elective’ and ‘deemed’ domicile.
Exclusive Residence and domicile
  • eBook chapter
  • 2024
  • Robin Vos
A chapter examining the taxation implications of domicile, and of the residence position of individuals, trustees, personal representatives, and partnerships.
Exclusive Tax planning for the non-resident and non-domiciled
  • eBook chapter
  • 2024
  • Mark McLaughlin
  • Tax Planning
A chapter on tax planning for the non-resident and non-domiciled, highlighting tax planning opportunities and potential pitfalls.
Exclusive The international dimension
  • eBook chapter
  • 2024
  • Rachael Brown
  • Personal Tax Planning
Three chapters providing tax planning advice related to domicile, residence, international tax and double tax relief.
Exclusive International tax and investment service
  • eBook
  • 2024
  • Dennis Campbell
  • International Tax and Investment Service
Country-by-country information on a range of important areas of international tax law, updated by two issues annually.
Exclusive Transfer pricing
  • eBook chapter
  • 2024
  • Satwaki Chanda, Steve Collings, Jacquelyn Kimber, Maria Kitt, David O'Keefe, Andrew Parkes
  • Corporation Tax
A full chapter providing practical guidance on transfer pricing, including the OECD BEPS project and the UK transfer pricing rules.
Terms of use

You are permitted to access, download, copy, or print out content from eBooks for your own research or study only, subject to the Acceptable usage terms.

Articles and books in the ICAEW Library collection

The collection of the ICAEW Library & Information Service includes a range of articles, books and reports on international taxation. A selection of general works on this topic is set out below.
International tax primer
  • Library book
  • 2023
  • B.J. Arnold
  • Kluwer Law International
This book offers an introductory analysis of the challenges countries encounter when designing international tax rules and coordinating them with the tax systems of their trading partners. It includes examples from both developed and developing nations.
Principles of international taxation, 9th ed.
  • Library book
  • 2023
  • L. Oats
  • Bloomsbury Professional
This book provides a clear introduction to international taxation. It covers policy, legal issues and planning points, primarily from the viewpoint of a multinational group of companies. Examples and diagrams are given throughout.
Tolley's international tax planning, 2023-24
  • Library book
  • 2023
  • A. Seidler, I. Butt, D. Nott
  • LexisNexis
This book sets the UK tax system in the context of international treaties and the international legal framework, examining issues such as permanent establishment, hybrids, EU law, thin capitalisation, interest deductions, withholding taxes, transfer pricing and information exchange. It includes a summary of the OECD's work on Pillar One and Pillar Two, along with a detailed treatment of the UK's implementation of Pillar Two. Examples, tables and checklists are included to aid understanding.

To find out how you can borrow books from the Library please see our guide to borrowing books.

You can obtain copies of articles or extracts of books and reports through our document supply service.

Further support

TAXconnect
  • Listing
  • 06 Mar 2015
Search for a consultant to help you with a specific technical tax problem. TAXconnect works on a telephone ‘hotline’ system, whereby consultants offer advice to fellow Tax Faculty members on tax problems for a nominal fee.
Tax Faculty
  • Hub page
  • 10 May 2018
Find out more about the Tax Faculty and upcoming events. Faculty members can access exclusive content, including TAXline, TAXguides, webinars, representations and support schemes.
Can't find what you're looking for?

The ICAEW Library can give you the right information from trustworthy, professional sources that aren't freely available online. Contact us for expert help with your enquiries and research.

Information

Some of the content on this web page was provided by the Chartered Accountants’ Trust for Education and Research, a registered charity, which owns the library and operates it for ICAEW.