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Author: Ronald Hein
Publisher: Kluwer Law International B.V.
ISBN: 9403519800
Category : Law
Languages : en
Pages : 314
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Book Description
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 International Compliance Assurance Programme (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 jurisdictions. This book is the first to investigate Co-operative Compliance alongside with the ICAP, describing developments in twelve countries (Australia, Austria, Canada, Germany, Italy, Japan, the Netherlands, Norway, Poland, Spain, the United Kingdom, and the United States). Following a general introduction, two opening perspectives on the ICAP are presented, one from the OECD and one 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; the 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. Country reports are contributed by tax professionals and tax academics experienced in dealing with Co-operative Compliance and the ICAP. Each report addresses the same questions, so that all the reports cover the same features of domestic relationship approaches and the ICAP. A final chapter reviews the collected 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. It will be welcomed by all stakeholders in the international tax community, including lawyers, taxation authorities and academics.
Author: Ronald Hein
Publisher: Kluwer Law International B.V.
ISBN: 9403519800
Category : Law
Languages : en
Pages : 314
Get Book Here
Book Description
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 International Compliance Assurance Programme (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 jurisdictions. This book is the first to investigate Co-operative Compliance alongside with the ICAP, describing developments in twelve countries (Australia, Austria, Canada, Germany, Italy, Japan, the Netherlands, Norway, Poland, Spain, the United Kingdom, and the United States). Following a general introduction, two opening perspectives on the ICAP are presented, one from the OECD and one 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; the 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. Country reports are contributed by tax professionals and tax academics experienced in dealing with Co-operative Compliance and the ICAP. Each report addresses the same questions, so that all the reports cover the same features of domestic relationship approaches and the ICAP. A final chapter reviews the collected 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. It will be welcomed by all stakeholders in the international tax community, including lawyers, taxation authorities and academics.
Author: Ronald Russo
Publisher:
ISBN:
Category :
Languages : en
Pages :
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Book Description
In this article, the authors examine the OECD's International Compliance Assurance Programme (ICAP) and whether the ICAP can be regarded as an attempt to introduce an international and multilateral cooperative compliance regime.
Author: J.M. Calderón Carrero
Publisher:
ISBN:
Category :
Languages : en
Pages :
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Book Description
This article examines the OECD's International Compliance Assurance Programme (ICAP) and considers whether it constitutes just a new model for tax control in relation to multinational enterprises or whether it could also be considered the basis of an unprecedented dispute-prevention mechanism that can reduce the level of transfer pricing controversies and stabilize the post-BEPS framework.
Author: Jeffrey Owens
Publisher: Kluwer Law International B.V.
ISBN: 9403531940
Category : Law
Languages : en
Pages : 152
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Book Description
National taxation authorities around the world are rapidly improving international cooperation, given the unprecedented triple impact of persistent revelations of large-scale corporate tax avoidance, the ever-increasing intricacies of digital cross-border transactions, and the unprecedented revenue deficits engendered by the COVID-19 pandemic. There is also a growing recognition that improving tax compliance needs to be reconciled with a legitimate desire on the part of businesses to have some certainty about their taxes. Cooperative compliance is one way to achieve that. This first analysis of the details of cooperative compliance programmes currently in operation describes tax control frameworks, suggests practical examples to assist practitioners in tax administrations and the private sector, and provides multiple perspectives on the design and legitimacy of such programmes. Drawing on detailed information contributed by tax practitioners and academics from a wide range of jurisdictions worldwide, the book identifies and explains certain crucial elements of successful programmes: the criteria for access to cooperative compliance (e.g., is the programme voluntary or mandatory? Is there a financial threshold? Will the criteria be publicly available?); model legislation that can facilitate the operation of such programmes (statutory provisions, administrative rules and procedures, etc.); the foundations for an international agreement on an audit assurance standard for tax control frameworks (including the role of the Organisation for Economic Co-operation and Development (OECD), the European Union (EU), and other international organizations); how to develop a methodology to measure the cost and benefits of cooperative compliance programmes; detailed case studies of existing compliance programmes in Australia, Austria, China, Germany, Italy, Poland, and Russia; and how to communicate a cooperative compliance programme to obtain trust from society. The analysis draws on two years of work led by WU Global Tax Policy Center (GTPC) at Vienna University of Economics and Business in cooperation with the International Chamber of Commerce (ICC) and the Commonwealth Association of Tax Administrators (CATA). The project brought together over two hundred people from 25 countries, including public officials, businesses, and academics. Tax certainty and predictability are key components for providing a tax environment that is conducive to cross-border trade and investment, and, in the long term, it is in the interest of both governments and businesses to minimize tax uncertainty as much as possible. This truly helpful book promises to pave the way to an internationally effective tax framework that will be welcomed by taxation authorities and practitioners worldwide.
Author: A. Majdańska
Publisher:
ISBN:
Category :
Languages : en
Pages :
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Book Description
In this article, the authors discuss how taxpayers and tax authorities alike can use impact evaluation to examine the effects of cooperative compliance programs. More specifically, they consider how to design an impact evaluation that can thoroughly assess the outcomes of the International Compliance Assurance Program (ICAP), a new project that the OECD hopes will provide early certainty, offer assurances regarding tax obligations, and promote the efficient use of resources by both tax administrations and taxpayers.
Author: B. Heidecke
Publisher:
ISBN:
Category :
Languages : en
Pages :
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Book Description
The authors discuss the International Compliance Assurance Program (ICAP) of the OECD.
Author: S. Araki
Publisher:
ISBN:
Category :
Languages : en
Pages :
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Book Description
In this article, the author discusses the background, significance, and potential implications of the International Compliance Assurance Programme (ICAP), a pilot initiative recently launched under the auspices of the OECD.
Author: OECD
Publisher: OECD Publishing
ISBN: 9264253386
Category :
Languages : en
Pages : 38
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Book Description
This report outlines the essential features of a Tax Control Framework (TCF) and addresses revenue bodies’ expectations of TCFs.
Author: M.H. Martini
Publisher:
ISBN:
Category :
Languages : en
Pages :
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Book Description
In this article, the authors review the progress that the OECD has made in instituting and revising its International Compliance Assurance Programme (ICAP) and suggest ways in which the ICAP could be improved in the future.
Author: OECD
Publisher: OECD Publishing
ISBN: 9264200851
Category :
Languages : en
Pages : 110
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Book Description
This report examines the relationship between large business taxpayers and revenue bodies, five years on from the publication of the FTA’s Study into the Role of Tax Intermediaries.
