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International taxes

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

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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 profit sharing, commonly known as BEPS, within international taxation.
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
OECD announces delay to global digital services tax framework
  • Article
  • 21 Oct 2020
21 October 2020: UK digital services tax will continue for longer than originally anticipated after OECD decision to extend discussions until mid-2021 ICAEW’s Tax Faculty reports.
Delay to DAC6 exchange of information
  • Article
  • 11 May 2020
11 May: European Commission (EC) proposes three-month postponement of the exchange of information under the Directive on Administrative Cooperation (DAC6) due to the coronavirus.
Exclusive Instrumental measures for private clients
  • Article
  • 25 Mar 2020
Base Erosion and Profit Shifting is an issue for large multinationals isn’t it? Seamus Murphy explains the relevance of the multilateral instrument to private clients.
OECD initiative on international corporate taxation
  • Article
  • 02 Mar 2020
Pillars One and Two are OECD’s response for a need to address international tax reform for digital economies across the globe.
Exclusive Practical points 2020 - International taxes
  • Article
  • 10 Jan 2020
Guidance from ICAEW's Tax Faculty for practitioners on the latest developments in practice, policy and legislation related to international taxes.
Corporation Tax and the General Election of 2019
  • Article
  • 26 Nov 2019
Politicians focus too much on the rate and not enough on the yield and wider impact of a coherent CT strategy

DAC 6 and tax disclosure

Practical guidance and support on the EU's tax disclosure regime, DAC6, and the OECD’s mandatory disclosure regime.

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.
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.
DAC 6 to be replaced by OECD rules for UK intermediaries from 2021
  • Article
  • 31 Dec 2020
4 January 2021: HMRC has confirmed that the UK will no longer be applying DAC 6 in its entirety following conclusion of the Free Trade Agreement with the EU. Only arrangements that would have fallen within Category D of DAC 6 will now need to be reported, in line with the OECD’s mandatory disclosure rules.
Red flags to navigate DAC 6 hallmarks
  • Article
  • 15 Dec 2020
15 December 2020: With the first reporting deadline less than two months away, Simon Bird from BDO LLP talks through a risk-based approach to compliance with DAC 6, highlighting practical ways in which entities can recognise the classes of arrangements which might be subject to these rules.
ICAEW members urged to prepare for DAC 6
  • Article
  • 06 Oct 2020
6 October 2020: ICAEW’s Tax Faculty is urging members not to be complacent ahead of 30 January 2021 reporting deadline for the new complex, EU disclosure regime.
ICAEW raises concerns about POTAS and DAC 6 interaction
  • Article
  • 21 Sep 2020
21 September 2020: ICAEW has asked HMRC to consider appropriateness of including DAC 6 failures in the promoters of tax avoidance schemes (POTAS) rules.
DAC 6: Disclosable arrangements - common questions and misconceptions
  • Article
  • 03 Jul 2020
ICAEW’s Tax Faculty explains why all ICAEW members need to be alert to their potential reporting obligations. Highlighting common misconceptions and answering frequently asked questions about the regime.
Exclusive Taxing times: The implication of DAC 6 on financial services
  • Article
  • 24 Jul 2019
The EU Directive DAC 6 means that firms operating in the EU will need to notify tax authorities of certain cross-border arrangements. Jason Collins and Catherine Robins look at the implications this will have on firms

Digitalisation of tax: international perspectives

Find out how digital technology 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:

  • 12 case studies from around the world
  • The benefits of pre-populating tax returns
  • The importance of data analytics
Find out more Download the report
Cover of the 2019 edition of ICAEW's Digitalisation of Tax - International Perspectives report

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
How can I find a double tax treaty?
  • Helpsheets and support
  • 10 Jan 2014
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.
Engagement letters helpsheet
  • Helpsheets and support
  • 01 Jul 2016
  • DOCX (237kb)
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? 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.

Residence and domicile

Support from ICAEW on residence and domicile in the UK personal tax regime, including offshore investments.
Exclusive Determining domicile as a preliminary issue
  • Article
  • 03 Mar 2023
Andrew Cockman reviews the continuing litigation by Epaminondas Embiricos concerning the point at which a taxpayer’s domicile should be established in the litigation process.
Tax news in brief 6 July
  • Article
  • 05 Jul 2022
Highlights from the broader tax news for the week ending 6 July 2022, including: L-Day; tax credit renewals; ID for government gateway; HMRC survey on forms; residence indicator tool; CHIEF closed to new importers; and an updated partial exemption toolkit.
Excluded property and the IHT spouse exemption
  • Article
  • 02 Mar 2021
HMRC has agreed an analysis of when the inheritance tax spouse exemption is available for assets held in a trust which are treated as beneficially owned by the settlor as a result of the reservation of benefit rules.
COVID-19: Employer returns accepted via email
  • Article
  • 29 May 2020
29 May 2020: Employers can file their Appendix 4, 7A and 7B end-of-year reports by email, HMRC has confirmed.
Covid-19: Changes to the statutory residence test
  • Article
  • 14 Apr 2020
14 April 2020: Chancellor relaxes tax residence test for skilled workers coming to the UK to help tackle the coronavirus pandemic.
Exclusive What are the consequences of gifting property to a UK non-resident trust?
  • Helpsheets and support
  • 05 Apr 2018
FAQ on whether a capital gain from a gifted property can be held over and whether there will be any consequences.
TAXguide 07/18: Deemed domicile changes – trust protections
  • Technical release
  • 27 Mar 2018
Finance (No 2) Act 2017 introduced significant changes to the taxation of foreign domiciliaries. In TAXguide 06/18 ICAEW, STEP, the CIOT and the Law Society have published questions and draft suggested answers to highlight and consider areas of uncertainty in the statutory provisions for trust protections. Read a summary and download the full guide.
TAXguide 07/18 Deemed domicile changes - trust protections
  • Technical release
  • 27 Mar 2018
  • PDF (460kb)
Finance (No 2) Act 2017 introduced significant changes to the taxation of foreign domiciliaries. In TAXguide 07/18 ICAEW, STEP, the CIOT and the Law Society have published questions and draft suggested answers to highlight and consider areas of uncertainty in the statutory provisions for trust protections.

Transfer pricing

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

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?
Demand for UK Tax Accountants Highest in Two Years
  • Article
  • 28 Jun 2021
Morgan McKinley and Vacancysoft review the increased search for tax accountants.
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.
Tax news in brief
  • Article
  • 18 Dec 2020
Highlights from the broader tax news week ending 22 December, which includes: guidance from HMRC on disguised remuneration schemes that avoid tax by selling business revenues to trusts, changes to land transaction tax and Royal Assent of the Taxation (Post-transition Period) Bill 2020.
Exclusive Transfer pricing and the COVID-19 pandemic
  • Article
  • 31 Jul 2020
Jonathan Schwarz of Temple Tax Chambers takes an in-depth look at why businesses might need to review their pricing arrangements in light of the global COVID-19 pandemic, including key practical takeaways.
OECD initiative on international corporate taxation
  • Article
  • 02 Mar 2020
Pillars One and Two are OECD’s response for a need to address international tax reform for digital economies across the globe.
Exclusive Practical points 2020 - International taxes
  • Article
  • 10 Jan 2020
Guidance from ICAEW's Tax Faculty for practitioners on the latest developments in practice, policy and legislation related to international taxes.

Bloomsbury Accounting and Tax Service

Eligible firms have free access to Bloomsbury Professional's comprehensive online library, comprising more than 60 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 Transfer pricing
  • eBook chapter
  • 01 Feb 2023
A full chapter providing practical guidance on transfer pricing, including the OECD BEPS project and the UK transfer pricing rules.
Exclusive International succession laws
  • eBook
  • 01 Jan 2023
Practical A-Z looseleaf providing information on international legal, tax and succession systems by country.
Exclusive Tax planning for the non-resident and non-domiciled
  • eBook chapter
  • 01 Dec 2022
A chapter on tax planning for the non-resident and non-domiciled, highlighting tax planning opportunities and potential pitfalls.
Exclusive Residence, domicile and UK taxation
  • eBook
  • 01 Aug 2022
Authoritative, in-depth guidance on the law of residence for tax of individuals, companies, trusts and partnerships.
Exclusive The international dimension
  • eBook chapter
  • 01 Jun 2022
Three chapters providing tax planning advice related to domicile, residence, international tax and double tax relief.
Exclusive International tax and investment service
  • eBook
  • 01 Apr 2022
Country-by-country information on a range of important areas of international tax law, updated by two issues annually.
Exclusive Transfer pricing practice
  • eBook chapter
  • 01 Sep 2021
A chapter on transfer pricing, providing an introduction to its key principles, OECD guidelines, transfer pricing methods and the Arm's Length Principle.
Exclusive Transfer pricing administration
  • eBook chapter
  • 01 Sep 2021
A chapter on transfer pricing administration, covering the documentation requirements before looking at dispute resolution, the penalties that can apply in transfer pricing cases and finally, the use of advanced pricing arrangements and other forms of cooperation.
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.

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 and Faculties Online subscribers on tax problems for a nominal fee.
Tax Faculty Find out more about the Tax Faculty and upcoming events. Faculty members can access exclusive content, including TAXline, TAXguides, webinars, representations and support schemes.
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