BEPS | International Taxes

Practical guidance

ICAEW's Tax Faculty produces TAXguides to provide practical support on technical areas of tax. See all TAXguides.

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.

Features and articles

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.

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.

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

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

Representation
15 Dec 2020
PDF (190kb)

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.

ICAEW REP 109/20 International regulatory cooperation

Representation
25 Nov 2020
PDF (148kb)

A response dated 25 November 2020 to a consultation published by BEIS on 2 September 2020.

ICAEW REP 126/19 Base erosion and profit shifting (BEPS): a unified approach under Pillar One

Representation
06 Dec 2019
PDF (133kb)

A response dated 12 November 2019 to a consultation published by OECD on 9 October 2019.

ICAEW REP 32/19 - Addressing the tax challenges of the digitalised economy

Representation
07 Mar 2019
PDF (280kb)

A response dated 6 March 2019 to a consultation published by OECD on 13 February 2019.

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 Beyond BEPS 1.0

eBook chapter
2023
Lynne Oats
Principles of International Taxation

A chapter outlining the OECD's BEPS 2.0 project, which builds upon the earlier BEPS 1.0 initiative.

Exclusive Principles of international taxation

eBook
2023
Lynne Oats
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.

Exclusive Anti-avoidance rules: structure

eBook chapter
2023
Lynne Oats
Principles of International Taxation

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.

Exclusive Anti-avoidance rules: finance

eBook chapter
2023
Lynne Oats
Principles of International Taxation

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.

Exclusive Tax avoidance and BEPS

eBook chapter
2023
Lynne Oats
Principles of International Taxation

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.

Exclusive Improper use of treaties

eBook chapter
2023
Lynne Oats
Principles of International Taxation

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.

Exclusive Transfer pricing

eBook chapter
2023
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.

Industry press

The ICAEW Library & Information Service provides access to a range of leading tax journals. These journals are available to logged-in ICAEW members, ACA students and other entitled users subject to suppliers' terms of use.

Exclusive Innovation and flexibility key to pillar two data readiness

Article
Oct 2023
Russell Gammon

With the Pillar Two deadline approaching, Russell Gammon argues that businesses ought to act now in order to effectively manage an increasingly complex set of data requirements.

Exclusive Multilateral instruments from BEPS 1.0 to BEPS 2.0

Article
Aug 2023
Paolo Ludovici, Marlinda Gianfrate

Article examining the evolution of multilateral tax instruments as one aspect of the BEPS 2.0 reform package.

Exclusive Canada wants DST feedback amid US objections

Article
Aug 2023

The Canadian government is set to introduce a digital services tax in January 2024 because it can't wait any longer for progress on the OECD's efforts to secure pillar one.

Exclusive BEPS 2.0 implementation: advances in Asia-Pacific and the China perspective

Article
May 2023
Sunny Leung, Conrad Turley

Sunny Leung and Conrad Turley of KPMG China survey the implications of the BEPS 2.0 rollout across the Asia-Pacific region. They consider particular jurisdictions in turn, and set out points of focus for businesses operating in the region.

Exclusive BEPS 2.0: high time to change the spreadsheets and sweep away the old

Article
May 2023
Phil Myers

As the implementation of the OECD's Pillar 2 proposals gathers pace, Phil Myers considers the challenges it could create for companies, how it might impact the role of tax professionals, and how technology might help to smooth the transition.

Exclusive Ireland opts for QDMTT regime by 2024

Article
Apr 2023

The Irish government is to commit to a QDMTT on Wednesday, April 5, as part of its support for the OECD's two-pillar solution.

Exclusive Korean companies stay cautious despite pillar two push

Article
Feb 2023
Ralph Cunningham

A steady stream of countries has announced steps towards implementing pillar two, but Korea has got there first. Ralph Cunningham finds out what tax executives should do next.

Exclusive OECD members make progress on harmful tax practices

Article
Feb 2023
Ralph Cunningham

An outline of the results of a monitoring exercise conducted by the Centre for Tax Policy and Administration (CTPA), which showed that a number of jurisdictions have made progress in implementing the international standard under BEPS Action 5 to address harmful tax practices.

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, 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.

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.

The Oxford handbook of international tax law

Library book
2023
F. Haase, G. Kofler (eds.)
Oxford University Press

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.

International tax arbitrage and the UK anti-hybrid rules

Library book
2022
M. Stringer
LexisNexis

A Tax Digest from Tolley, examining the anti-hybrid rules that have been created to tackle the potential tax advantages arising from differences in treatment between the UK and a second jurisdiction.

Useful links

BEPS developments tracker

Website
21 Mar 2018

Tool that enables users to browse and filter summaries of BEPS developments by date, location and related Action.

PwC: Base Erosion and Profit Shifting (BEPS) Action Plan

Website
20 Mar 2018

Commentary and timeline with links to relevant documents on each BEPS action providing a detailed summary of OECD and government activity.

OECD: Base erosion and profit shifting

Website
16 Mar 2018

Background information on the Inclusive Framework on BEPS and documents relating to each of the 15 BEPS Actions to help governments tackle multinational tax avoidance strategies.

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.