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International Compliance Assurance Programme Pilot for Transfer Pricing Launched

The OECD has announced the launch of the International Compliance Assurance Programme (ICAP) on 23 January 2018 with eight members of the OECD Forum on Tax Administration taking part, including Australia, Canada, Italy, Japan, the Netherlands, Spain, the United Kingdom, and the United States.

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23/01/2018 - A pilot of a new FTA programme for the multilateral risk assessment of large MNE groups was launched at an event today in Washington DC. The International Compliance Assurance Programme (ICAP) is a pilot for a voluntary programme that will use CbC Reports and other information to facilitate open and co-operative multilateral engagements between MNE groups and tax administrations, with a view to providing early tax certainty and assurance.

By co-ordinating conversations between an MNE group and tax administrations in several jurisdictions, the programme should also ensure a more effective use of transfer pricing information (including that contained in a group's CbC report, master file and local file), a more efficient use of resources both for the MNE group and for tax administrations and, in the longer term, fewer cases entering into mutual agreement proceedings (MAP). ICAP has been developed under the framework of the OECD Forum on Tax Administration (FTA) Large Business and International Programme, sponsored by the Canada Revenue Agency (CRA).

A pilot for ICAP, which includes eight FTA member tax administrations (Australia, Canada, Italy, Japan, the Netherlands, Spain, the United Kingdom and the United States), was launched at a participant orientation event, introduced by Mr. David Kautter, acting Commissioner of the IRS, and Mr. Bob Hamilton, Commissioner of the CRA. A multilateral assessment of specific international tax risks posed by each MNE group in the pilot will commence during the first half of 2018 and is expected to be completed within a target timeframe of 12 months. A handbook which provides more detail on ICAP and the procedure for the pilot was also launched at the event.

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