Taxation

Co-operative Compliance and the OECD's International Compliance Assurance Programme

Edited by Ronald Hein · Ronald Russo
Kluwer Law International May 2020

Specifications

ISBN-13
9789403519517
Publisher
Kluwer Law International
Publication
May 2020
Format
Hardback
Jurisdiction
Netherlands ? Countri(es) for reference only

Details

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.

What’s in this book:

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.

How this will help you:

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.

Table of Contents

Preface
CHAPTER 1. Introduction: An Investigation of Co-operative Compliance Regimes and the ICAP
Mário H. Martini
CHAPTER 2. International Compliance Assurance Programme
Achim Pross & Mark Johnson
CHAPTER 3. The ICAP Experience: From a Tax Authority Perspective
Hans Rijsbergen
CHAPTER 4. Co-operative Compliance Programmes in Australia: Working Towards Justified Trust
Celeste M. Black
CHAPTER 5. Co-operative Compliance: An Austrian Point of View
Simon Hofstätter
CHAPTER 6. Canada’s Experience with the ICAP
Allison Christians & Tarcísio Diniz Magalhães
CHAPTER 7. Does Co-operative Compliance Fit into the German Compliance Environment?
Andreas Kowallik & Wouter de Ruiter
CHAPTER 8. From Tax Rulings to Co-operative Compliance: A New Deal Between the Taxpayer and the Italian Tax Administration?
Francesco Cannas & Mario Grandinetti
CHAPTER 9. Japanese International Compliance Assurance in Practice
Yasuyuki Kawabata
CHAPTER 10. Co-operative Compliance in Norway
Benedicte Brøgger & Kiran Aziz
CHAPTER 11. Co-operative Compliance and ICAP in the Netherlands
Ronald Russo
CHAPTER 12. Co-operation Programme: A Novelty in the Polish Tax System
Malgorzata Sek
CHAPTER 13. Hard Law and Soft Law Measures Implemented by Spain Regarding Co-operative Compliance
J. Carlos Pedrosa López
CHAPTER 14. Co-operative Compliance: The U.K. Evolutionary Model
Dennis de Widt & Lynne Oats
CHAPTER 15. The U.S. Compliance Assurance Programme and Comparative Lessons
George Clarke & Joy Williamson
CHAPTER 16. Preventing Double Taxation: Analysis of Recent Developments and ICAP 2.0
Taco Wiertsema & Freek Braken
CHAPTER 17. Concluding Remarks and Observations
Ronald Russo
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