Practical guidance
ICAEW's Tax Faculty produces TAXguides to provide practical support on technical areas of tax.
See all TAXguides.
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TAXguide 06/23: A basic guide to pillar two
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.
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.
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Principles of international taxation
A clear introduction to international taxation which also provides more in-depth material on many essential areas. Fully updated to cover all new tax legislation and developments, including those in light of the ongoing OECD BEPS project implementation.
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Anti-avoidance rules: structure
A chapter covering two kinds of anti-avoidance rules which aim to tackle some of the tax avoidance techniques used by multinational entities: controlled foreign companies (CFC) legislation, and anti-hybrid rules relating to entity mismatches.
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International tax avoidance and BEPS 1.0
A chapter reflecting on how the OECD’s work on base erosion and profit shifting (BEPS) has aimed to tackle corporate tax avoidance, and outlining the outcomes of the BEPS 1.0 project.
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Anti-avoidance rules: finance
A chapter discussing the interest restriction rules that some countries have adopted in an attempt to prevent multinational entities from using intra-group financial arrangements to reduce their group tax liabilities.
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Improper use of treaties
A chapter exploring some of the most common corporate structures used for the purpose of abusing bilateral tax treaties, as well as the common approaches to preventing such improper practices.
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Beyond BEPS 1.0
A chapter looking at BEPS 2.0, also known as the ‘Two Pillar Solution’ and the ‘Global Tax Deal’. It offers a basic overview of the very complex set of rules associated with Pillar One and Pillar Two, as well as related issues.
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Transfer pricing
A full chapter providing practical guidance on transfer pricing, including the OECD BEPS project and the UK transfer pricing rules.
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 base erosion and profit shifting. A selection of books on this topic is set out below.
Tolley's international tax planning, 2025-26
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.
Principles of international taxation, 9th ed.
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.
The Oxford handbook of international tax law
This handbook traces the history of international tax law from its earliest days until the present. It includes coverage of the key issues in this area today, including tax transparency, minimum corporate taxation, the tackling of Base Erosion and Profit Shifting (BEPS), and the reconstruction of the network of bilateral tax treaties.
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.
Representations
ICAEW publishes its responses to HMRC and government consultations on tax policy and practice as representations. See all tax representations.
ICAEW REP 113/20 BEPS Pillar one and two blueprints
ICAEW's response, dated 14 December 2020, to a consultation published by OECD on 12 October 2020 outlining proposals to Pillars One and Two. The proposals focus on providing international consensus for taxing the digital economy.