Use a flexible powdered adhesive suitable for porcelain tiles and it should stick no problem. But dare I ask why you want to do this?
As always, I recommed 25mm WBP for an ideal floor to tile onto when replacing floorboards; or 12mm WBP when overboarding. Have a look at the sticky thread for fixing details.
Personally I would shy away from wall tiling onto ply in any wet situation due to the fact that it is inherently unstable with changes in atmospheric conditions. Tanked plasterboard would be better.
If you're talking about floors, then I would leave the decision up to you about the suitability of an epoxy "resin" - that's not what we generally do you see. Although I can say that a porcelain adhesive should stick fine to an epoxy resin, I cannot vouch for the ability of epoxy resin to provide a waterproof barrier. What I would say is that anything is better than nothing.
If you need to find a tradesperson to get your job done, please try our local search below,
or if you are doing it yourself you can find suppliers local to you.
Select the supplier or trade you require, enter your location to begin your search.
Please select a service and enter a location to continue...
Are you a trade or supplier? You can create your listing free at DIYnot Local