The constant feature in international tax is the ever-changing environment. As countries continue with their implementation of Pillar Two’s global minimum tax, the BEPS project moves from anti-avoidance measures to the implementation of a new tax. Although many international businesses will be below the size thresholds of Pillar One and Pillar Two, it is certain that the measures will have a wider impact than what may have been anticipated when the OECD returned to the subject of the digital economy; principles developed by the Inclusive Framework working parties are increasingly influencing the development of policy elsewhere, for example within the EU.

Multi-national enterprises of all sizes will look to ensure their governance of tax matters is founded on a firm understanding and application of principles; it remains that fiscal authorities, charged with raising tax revenues and closing the tax gap, continue to focus on risks they perceive to arise from international arrangements.

This extensive work, fully updated to April 2025 by Andrew Seidler, Irfan Butt and Paul Minness of RSM, examines the major issues of the day in international tax planning including permanent establishment, hybrids, EU law, thin capitalisation, interest deductions, withholding taxes, transfer pricing and information exchange.

New to this edition:

• Fully updated for Finance Act 2025;

• Updated for the residence based rule for determining worldwide taxation of individuals, and the abolition of the remittance basis;

• Updated for tracking of the Pillar One and Pillar Two developments through the Inclusive Framework;

• Updated for the implementation internationally od Pillar One measures;

• Updated for the UK implementation of Pillar Two IIR and UTPR;

• Commentary on policy proposals from the UK, EU and OECD;

• Updated for important case law decisions.



Each key topic is illustrated with short examples, tables and checklists.