The International Compliance Assurance Programme And Joint Audits A New Epoch Of Transfer Pricing Tax Audits
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Author | : B. Heidecke |
Publisher | : |
Total Pages | : |
Release | : 2018 |
Genre | : |
ISBN | : |
This article discusses two new, internationally coordinated regulations that address the problem of double taxation: the joint tax audit and the International Compliance Assurance Programme. It gives an outlook on whether those two measures could start a new epoch of transfer pricing tax audits.
Author | : Ronald Hein |
Publisher | : Kluwer Law International B.V. |
Total Pages | : 314 |
Release | : 2020-06-10 |
Genre | : Law |
ISBN | : 9403519800 |
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 | : OECD |
Publisher | : OECD Publishing |
Total Pages | : 96 |
Release | : 2017-09-29 |
Genre | : |
ISBN | : 9264282181 |
This report examines how tax compliance strategies are evolving in light of new technologies, data sources and tools and also looks at how these changes might affect the role of audit and auditors in the future.
Author | : J.M. Calderón Carrero |
Publisher | : |
Total Pages | : |
Release | : 2018 |
Genre | : |
ISBN | : |
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 | : J. Li |
Publisher | : Springer |
Total Pages | : 204 |
Release | : 2007-01-10 |
Genre | : Business & Economics |
ISBN | : 0230595812 |
This book focuses on the practice of transfer pricing audits which the Chinese government operates in the case of the vast number of foreign enterprises operating in the Chinese economy. It includes the testimony of Chinese officials about their work, material that given the secrecy of Chinese business and culture, is difficult to come by.
Author | : |
Publisher | : |
Total Pages | : |
Release | : 2019 |
Genre | : |
ISBN | : |
The past few years have seen many changes with respect to transfer pricing documentation, from the new country-by-country reporting (CbC) reporting rules to Master File/Local File requirements to tax return disclosures. This forum explores the impact that this increased global focus on transparency has had on the transfer pricing compliance process and the audit process. Respondents were asked to discuss challenges taxpayers face in preparing the detailed documentation required, as well as the ways tax authorities are adapting to the increased level of information available to them. QUESTIONS: 1. Briefly describe the transfer pricing documentation and tax return disclosure requirements in your jurisdiction; 2. In recent years, have the tax authorities changed or modified their audit approach? (e.g., increase in staffing and/or increase in funding with respect to the transfer pricing audit function; use of risk assessment tools or data mining tools to identify audit targets; use of joint or coordinated audits, etc.). If risk assessment tools are used, what factors are typically analyzed?; 3. Do the tax authorities focus on certain types of transactions? (e.g., intangibles, financing transactions, commodities, etc.); 4. Do the tax authorities rely on BEPS-related concepts during its audits? (e.g., DEMPE analysis, new approach for hard-to-value intangibles, expanded use of profit splits, use of risk assessment framework, etc.); 5. Do transfer pricing penalties apply in your jurisdiction? If so, what can be done to mitigate these penalties?; 6. Please describe any challenges taxpayers face in preparing their transfer pricing documentation in light of these changes in the audit process.
Author | : F. Vincent |
Publisher | : |
Total Pages | : |
Release | : 2018 |
Genre | : |
ISBN | : |
Before hailing the newly minted International Compliance Assurance Programme (ICAP) from the OECD as the panacea to resolve problems of double taxation for multinational enterprises (MNE), the authors thought it would be useful to review and compare the ICAP's salient features with those of other existing programs aimed at resolving double taxation. This paper provides a side-by-side comparison of the various multijurisdictional tools/programs available pursuant to double tax treaties to resolve double taxation in respect of transfer pricing transactions: mutual agreement procedure (MAP); advance pricing arrangements (APAs); simultaneous tax examinations; joint audits; and ICAP. Each of these programs is reviewed as it relates to the following topics: (1) goals; (2) parties; (3) process; (4) documentation required; (5) timing; (6) availability; (7) benefits; and (8) drawbacks.
Author | : Reyhaneh Safaei |
Publisher | : |
Total Pages | : 0 |
Release | : 2023 |
Genre | : |
ISBN | : |
Author | : OECD |
Publisher | : OECD Publishing |
Total Pages | : 355 |
Release | : 2021-09-15 |
Genre | : |
ISBN | : 9264424083 |
This report is the ninth edition of the OECD's Tax Administration Series. It provides internationally comparative data on aspects of tax systems and their administration in 59 advanced and emerging economies.
Author | : United States. Internal Revenue Service |
Publisher | : |
Total Pages | : 12 |
Release | : 1980 |
Genre | : Tax administration and procedure |
ISBN | : |