International tax update and refresher

The course begins by examining the principles of international tax, with a particular focus on the framework established by the OECD and how these principles are implemented across different jurisdictions, especially in the UK.

It then explores recent developments coming into effect from 31 December 2025.

Looking ahead, 2026 will see further progress in implementing elements of the BEPS 2.0 programme and the G7/G20 agreement on corporate taxation. In particular, the end of 2025 marked the introduction of the side-by-side agreement for Pillar Two, and the course will assess its impact on international corporate taxation.

On 19 November 2025, the OECD published new guidance for tax authorities on permanent establishments. These changes are expected to affect small and medium-sized businesses, particularly those concerned about inadvertently creating permanent establishments and triggering associated corporation tax obligations. If adopted by tax authorities, this guidance could provide greater clarity and support for businesses.

HMRC has also undertaken a review of transfer pricing and permanent establishment rules, with significant changes due to take effect in 2026 that will impact businesses with international operations.

In addition, the EU continues to advance its programme of international tax coordination, covering both VAT and corporate taxation, which businesses will need to understand.

The course also considers the impact of tax and tariff policies introduced during the Trump administration. This includes developments such as the withdrawal from Pillar Two, changes in tariff policy, and the introduction of Section 899, enacted to counter what the US considers unfair tax practices by other countries.