ICAP statistics and implications for businesses looking to obtain tax certainty
The Organisation for Economic Cooperation and Development (OECD) three years ago launched the International Compliance Assurance Programme (ICAP) as a permanent multilateral risk assessment of a multinational enterprise (MNE) group鈥檚 key international tax risks.
ICAP involves a review of selected transfer pricing and permanent establishment (PE) issues, and while it cannot provide true certainty in the manner of an advance pricing agreement (APA), it is designed to provide comfort and, where needed and feasible, to facilitate issue resolution without the need for a separate competent authority (CA) procedure.
Until the official release of ICAP statistics in January 2024听(谤别补诲听TaxNewsFlash), taxpayers听could assess ICAP only on the basis of听sparse anecdotal evidence. The ICAP statistics sheds light on what was largely a black box听and allows taxpayers to make informed choices with regard to tax certainty.
Read a听March 2024 report*听[PDF 95 KB] prepared by 乐鱼(Leyu)体育官网 LLP that discusses the ICAP statistics and their implications for businesses looking to obtain tax certainty.
* This article appears in听International Tax Review听and is provided with permission.