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TPI 4, August 2018, Seite 178

The OECD’s International Compliance Assurance Programme (Part II)

A Response to the Need for Multilateral Risk Assessment

Alicja Majdanska und Jonathan Leigh-Pemberton

The OECD has initiated a pilot programme called the International Compliance Assurance Programme (ICAP). This is the second part of a two-part contribution dealing with ICAP. It looks at ICAP itself and discusses its main design features such as the country-by-country report. Finally, it also examines the expected benefits and explores some challenges that may need to be addressed if the programme is to extend beyond the pilot phase.

1. Drivers for the Pilot

ICAP has been presented as a “multilateral cooperative risk assessment and assurance process”. It is a voluntary fast-track risk assessment process that is intended to enhance tax administrations’ individual risk assessment processes and provide large business taxpayers with increased certainty. More specifically, the Pilot Handbook, which was published at the outset of the pilot, identifies six main drivers for the programme.

The Pilot Handbook for ICAP explains that it is partly a response to the availability of “better and more standardised information for transfer pricing risk assessment”. As already mentioned, ICAP was preceded by many developments on the transparency agenda, including Action 13 of the BEPS project, which inc...

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