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BEPS

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

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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

HMRC helps businesses prepare for Pillar 2
  • Article
  • 22 Jul 2024
In its third Pillar 2 update, HMRC explains aspects of the rules and sets out its plans for the coming months, including the release of the next stage of its Pillar 2 online service.
HMRC explains pillar two tax registration in the UK
  • Article
  • 03 Jun 2024
Groups within the scope of pillar two must register with HMRC within six months after the end of the first accounting period to begin on or after 31 December 2023.
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.

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
A full chapter providing practical guidance on transfer pricing, including the OECD BEPS project and the UK transfer pricing rules.
Exclusive Tax avoidance and BEPS
  • eBook chapter
  • 2023
  • Lynne Oats
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 Beyond BEPS 1.0
  • eBook chapter
  • 2023
  • Lynne Oats
A chapter outlining the OECD's BEPS 2.0 project, which builds upon the earlier BEPS 1.0 initiative.
Exclusive Improper use of treaties
  • eBook chapter
  • 2023
  • Lynne Oats
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 Anti-avoidance rules: structure
  • eBook chapter
  • 2023
  • Lynne Oats
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
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 Principles of international taxation
  • eBook
  • 2023
  • Lynne Oats
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.
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 Pillar Two and nonprofit organizations
  • Article
  • Sep 2024
  • John Kelleher, Y. K. Chung
An examination of how the Pillar Two global anti-base erosion rules apply to nonprofit organisations.
Exclusive Pillar two necessary to boost tax revenues: Australian minister
  • Article
  • Aug 2024
Andrew Leigh tells ITR that the 15% minimum corporate tax is crucial to extracting revenue from multinationals that are misusing transfer pricing rules.
Exclusive Debunking common myths: BEPS Pillar Two preparation
  • Article
  • Jul 2024
  • Phil Myers
Amid legislative uncertainty, increased data challenges, and safe harbours laced with potential pitfalls, ITR hears some BEPS Pillar Two myths dispelled and learns how tax functions can get their preparations on track.
Exclusive Indonesian tax roundup: expanded reservations for BEPS Multilateral Instrument
  • Article
  • Jul 2024
  • Fabian Abi Cakra and Aditya Nugroho
Fabian Abi Cakra and Aditya Nugroho of GNV Consulting report that Indonesia's reservations now cover 13 countries, while new regulations have addressed export duty rates for metal mineral products and tax administration systems.
Exclusive Singapore opens consultation on landmark pillar two legislation
  • Article
  • Jul 2024
Interested parties may submit their comments on proposed bills and the subsidiary legislation by July 5.
Exclusive Elections may determine whether US introduces pillar two, report claims
  • Article
  • Jul 2024
Resources needed to manage new compliance and financial reporting requirements will be significant, BDO also said,
Exclusive BEPS 2.0: the implementation of Pillar Two in Asia-Pacific
  • Article
  • Jun 2024
  • Matt Andrew, et al.
Senior EY tax practitioners provide an update on the Pillar Two roll-out timetables across the region and consider various example scenarios as they assess the likely impact on multinational enterprises in 2024 and beyond.
Exclusive Your complete Pillar Two playbook
  • Article
  • May 2024
  • Gary Colbert
A guide to Pillar Two planning for multinational enterprises (MNEs). The author sets out four parallel steps that MNEs ought to take in order to tackle complexity, allocate resources, automate new processes, and more.

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.
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.

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
  • 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.

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 on tax problems for a nominal fee.
Tax Faculty
  • Hub page
  • 10 May 2018
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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