International taxes

BEPS

Expert commentary and practical guidance from ICAEW related to base erosion and profit shifting, commonly known as BEPS, within international taxation.

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

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.

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.

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 (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?

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.

Saqib Bhatti MP: digital identity verification on way

Article
29 Apr 2024

Following ICAEW’s Manifesto call for the UK to develop the skills to lead on AI, Saqib Bhatti MP discussed the government’s technology priorities in a conversation with CEO Alan Vallance.

ICAEW technical updates: March 2024

Article
26 Mar 2024

This month’s top stories include Spring Budget announcements, HMRC halting the decision to restrict helplines, and more guidance on the lifetime allowance abolition.

Draft legislation published for some Spring Budget 2024 measures

Article
18 Mar 2024

The Spring Finance Bill contains legislation which increases the thresholds for the high income child benefit charge and abolishes multiple dwellings relief for SDLT.

Non-dom regime replaced by foreign income and gains regime

Article
06 Mar 2024

In the Spring Budget, the Chancellor announced that the current remittance basis of taxation will be abolished for UK resident non-domiciled individuals from 6 April 2025 and replaced by a new four-year foreign income and gains (FIG) regime.

A pre-election Budget lacking in rabbits or hats

Article
06 Mar 2024

An extension of full expensing to leases is welcome news for businesses in a Budget that delivers nothing unexpected.

Exclusive Italy introduces new linking rules to define tax residence

Article
05 Feb 2024

Paolo Ludovici and Daniel Canola of Gatti Pavesi Bianchi Ludovici say several issues are resolved by revised criteria regarding the tax residence of legal entities, but the increase in remote working creates complications.

Exclusive Practical points: personal tax January 2024

Helpsheets and support
11 Jan 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 capital gains tax; income tax; and residence and domicile.

Exclusive Italy searching for new rules defining the tax residence of individuals

Article
02 Oct 2023

Paolo Ludovici and Andrea Gallizioli of Gatti Pavesi Bianchi Ludovici comment on the 'Delegation Law' recently passed by the Italian Parliament, which provides for a broad revision of the tax residence of natural persons.

Transfer pricing

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

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.

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.

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 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.

Exclusive Global transfer pricing: principles and practice (fifth edition)

eBook
2023
Roy Donegan
Global Transfer Pricing - Principles and Practice

Accessible introduction to transfer pricing – a complex and increasingly important area of business taxation.

Exclusive International succession laws

eBook
2023
Mark Bridges, David Way
International Succession Laws

Practical A-Z looseleaf providing information on international legal, tax and succession systems by country.

Exclusive Transfer pricing practice

eBook chapter
2023
Lynne Oats
Principles of International Taxation

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
2023
Lynne Oats
Principles of International Taxation

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

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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.

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.