Co-operative Compliance and the OECD’s International Compliance Assurance Programme is the first publication to analyse Co-operative Compliance and the International Compliance Assurance Programme (ICAP) in twelve different jurisdictions. Prominent among initiatives addressing the urgent need for a common understanding between multinational enterprises (MNEs) and national tax authorities about risks and risk assessment is the ICAP, which provides a channel for MNEs to engage in simultaneous discussions with multiple national tax administrations, thus enhancing the potential for advance tax assurance. To a certain extent, the ICAP represents the internationalization of Co-operative Compliance frameworks which were, until then, restricted within the borders of single jurisdiction.
Following a general introduction, the book presents two opening perspectives on the ICAP, one from the OECD and the other from a participating tax administration (the Netherlands), leading to the twelve country reports and a special chapter on transfer pricing, which is the main issue in international tax disputes.
Specific elements reviewed include the following:
- criteria to enter the programme;
- range of taxes covered by the programme;
- real-time consultation procedures;
- appeal procedures within the programme;
- the possibility to ‘agree to disagree’ and to continue Co-operative Compliance even in cases of litigation;
- risk-management strategies within tax authorities;
- corporate administrative compliance burden; and
- main sources of tax uncertainty.
Each report addresses the same questions so that all the reports cover, to some extent, the same features of their domestic relationship approaches and their ICAP experiences. A final chapter puts forward the reviews on the contributions and offers some concluding remarks.
Although the ICAP process probably will undergo further adjustments, it is certain that the road to more international cooperation between tax authorities and MNEs is now open. This timely book, as a comparative review of the implementation of the ICAP among leading jurisdictions active in global trade, provides matchless insights into trends, similarities, differences and their implications. With country reports contributed by tax academics and professionals experienced in dealing with Co-operative Compliance and the ICAP, this book will be welcomed by all stakeholders in the international tax community, including lawyers, taxation authorities and academics.
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Introduction: An Investigation of Co-operative Compliance Regimes and the ICAP
Mário H. Martini
International Compliance Assurance Programme
Achim Pross & Mark Johnson
The ICAP Experience: From a Tax Authority Perspective
Co-operative Compliance Programmes in Australia: Working Towards Justified Trust
Celeste M. Black
Co-operative Compliance: An Austrian Point of View
Canada’s Experience with the ICAP
Allison Christians & Tarcísio Diniz Magalhães
Does Co-operative Compliance Fit into the German Compliance Environment?
Andreas Kowallik & Wouter de Ruiter
From Tax Rulings to Co-operative Compliance: A New Deal Between the Taxpayer and the Italian Tax Administration?
Francesco Cannas & Mario Grandinetti
Japanese International Compliance Assurance in Practice
Co-operative Compliance in Norway
Benedicte Brøgger & Kiran Aziz
Co-operative Compliance and ICAP in the Netherlands
Co-operation Programme: A Novelty in the Polish Tax System
Hard Law and Soft Law Measures Implemented by Spain Regarding Co-operative Compliance
J. Carlos Pedrosa López
Co-operative Compliance: The U.K. Evolutionary Model
Dennis de Widt & Lynne Oats
The U.S. Compliance Assurance Programme and Comparative Lessons
George Clarke & Joy Williamson
Preventing Double Taxation: Analysis of Recent Developments and ICAP 2.0
Taco Wiertsema & Freek Braken
Concluding Remarks and Observations
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