Author Description

<p>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).</p> <p>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:</p> <ul> <li>criteria to enter the programme;</li> <li>the range of taxes covered by the programme;</li> <li>real-time consultation procedures;</li> <li>appeal procedures within the programme;</li> <li>the possibility to &lsquo;agree to disagree&rsquo; and to continue Co-operative Compliance even in cases of litigation;</li> <li>risk management strategies within tax authorities;</li> <li>corporate administrative compliance burden; and</li> <li>main sources of tax uncertainty.</li> </ul> <p>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 I