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

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 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.

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.

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 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 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 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 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 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 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 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.

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 Ten steps to build best BEPS-compliant policies for crypto clients

Article
Feb 2024
Pretino Albury

Tax advisers can't afford to ignore cryptocurrency if they want deeper client relationships, argues Pretino Albury of Kreston Global.

Exclusive Pillar one implications of amount B for businesses in Korea

Article
Feb 2024
Yong Chan Lee and Eun Jin Choi

Yong Chan Lee and Eun Jin Choi of Deloitte Korea provide an update on the application of the OECD's two-pillar solution and explain how Korean businesses can prepare for amount B's introduction.

Exclusive Navigating new terrain with multinational tax compliance

Article
Feb 2024
Don Reiser, Jan Smallenbroek

An overview of how the OECD's Pillar Two international corporate tax rules will impose significant new compliance obligations on mid-sized multinational enterprises.

Exclusive Pillars one and two: TP considerations for jurisdictions and MNEs

Article
Feb 2024
Sanjay Kumar, Suchint Majumdar

Sanjay Kumar and Suchint Majumdar of Deloitte India provide a guide to the BEPS package and explain why streamlining the calculation of amounts A and B is integral to its successful implementation.

Exclusive 'Sledgehammer to crack a nut': MHA expert on pillar two

Article
Feb 2024
Sam Sholli

The OECD's pillar two reforms mean a significant compliance burden for multinational companies, according to a senior tax partner.

Exclusive Public consultation opens on BEPS 2.0 implementation in Hong Kong

Article
Jan 2024
Lewis Lu, John Timpany

Lewis Lu and John Timpany of KPMG China discuss the potential implementation of the GloBE rules and a minimum top-up tax in Hong Kong from 2025.

Exclusive The GloBE knock-on effects of transfer pricing and other adjustments

Article
Jan 2024
Brian Jenn

An examination of the implications of transfer pricing adjustments in the context of Global Anti-Base Erosion (GloBE) regimes, particularly Pillar 2.

Exclusive US multinationals 'ready' for pillar two, says PwC tax leader

Article
Nov 2023

Pillar two rules are 'enormously complex' and have a lot of nuances but US multinationals are in a better position now, a senior industry figure tells ITR.

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
EY

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
PwC

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
OECD

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.