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  • International Compliance Assurance Programme (ICAP)

    The ATO is participating in the International Compliance Assurance Programme (ICAP) launched by the Organisation for Economic Co-operation and Development (OECD).

    ICAP involves various tax administrations undertaking cooperative multilateral risk assessments on multinational enterprises (MNEs) using Country-by-Country (CbC) reports and other information to assess transfer pricing and permanent establishment risks.

    The ICAP first pilot, launched in January 2018, involved eight of the OECD's Forum on Tax Administration (FTA) member tax administrations participating in the multilateral risk assessment of MNE groups with headquarters in one of their jurisdictions. The eight jurisdictions were Australia, Canada, Italy, Japan, the Netherlands, Spain, the United Kingdom and the United States.

    The second ICAP pilot, announced in March 2019, will include 17 participating jurisdictions (Australia, Austria, Belgium, Canada, Denmark, Finland, Germany, Ireland, Italy, Japan, Luxembourg, the Netherlands, Norway, Poland, Spain, United Kingdom and United States).

    Key benefits of ICAP include:

    • targeted and consistent interpretation and use of CbC reports
    • better use of resources for tax administrations and MNEs
    • a co-ordinated and transparent approach to engagement
    • faster multilateral tax certainty
    • fewer disputes entering into a mutual agreement procedures (MAP).

    The ATO and the other participating tax administrations have finalised the risk assessments under the pilot with the learnings from this process used to refine and improve the second pilot (ICAP 2.0).

    More information about ICAP 2.0, including a handbook for the multilateral risk assessments, can be found on the OECD websiteExternal Link.

    ICAP complements the ATO’s Top 100 risk categorisation approach and Top 1,000 tax performance program, as well as other initiatives, such as our advance pricing arrangement and advice and guidance programs to provide tax certainty to MNEs.

    For more information about the ATO’s involvement in ICAP email Australian multinationals that wish to discuss possible participation in ICAP 2.0 should contact us by 30 June 2019.

    See also:

      Last modified: 22 May 2019QC 55206