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Emerging Tax Compliance Programs
From ICAP to French Domestic Initiatives
On an international scale, the OECD International Compliance Assurance Programme (ICAP) addresses one-off cross-border issues by involving several tax administrations but does not provide any tax guarantee to taxpayers. On a domestic scale, the French tax compliance program helps obtaining tax certainty with the French tax administration on issues that enterprises face on an on-going basis.
1. Introduction
Recent years have shown different trends in the context of the OECD Base Erosion and Profit Shifting (“BEPS”) project and the fight against tax avoidance and evasion: strengthening of tax audits by tax administrations, increased transparency requested from the taxpayers and search for increased tax certainty by the taxpayers.
While tax administrations have strengthened tax audits, they also try to offer alternative tools to address tax issues with taxpayers before the launch of any formal audit as part of voluntary processes. This is the context in which both international and domestic tax compliance programs have been developed. These programs consist in collaborative processes between tax administrations and taxpayers to address contemporaneous tax issues. They aim at securing ta...