The OECD has initiated a pilot programme called the International Compliance Assurance Programme (ICAP). ICAP draws on the domestic concept of cooperative compliance. However, ICAP looks to apply the thinking behind cooperative compliance in a multilateral context and so help reduce tax uncertainty. In so doing, it extends the scope of cooperative compliance as a compliance tool. However, as we will see, the scope of ICAP is also more limited than its domestic counterpart.

This two-part contribution provides an initial snapshot of the new initiative. It presents the benefits it may bring and also highlights some initial concerns that may need to be addressed if ICAP is to realise its full potential. The first part begins with a short explanation of the concept of cooperative compliance in the domestic context. It presents the developments in the international arena that helped create a conducive environment for a multilateral cooperative compliance project. The second part, to be published in the TPI August issue, will look at ICAP itself and discuss its main design features. Finally, it will also examine the expected benefits and explore some challenges that may need to be addresse...