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  • International Compliance Assurance Programme (ICAP)

    The ATO is participating in the pilot of the International Compliance Assurance Programme (ICAP) launched by the Organisation of Economic Cooperation 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 relevant information to assess transfer pricing and permanent establishment risks.

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

    Key benefits of ICAP include:

    • Targeted and consistent interpretation and use of Country-by-Country Reports
    • Better use of resources for tax administrations and MNEs
    • Co-ordinated and transparent approach to engagement
    • Faster multilateral tax certainty
    • Fewer disputes entering into Mutual Agreement Procedures (MAP).

    The pilot was launched in January 2018. The ATO and the other participating tax administrations have now started meeting with MNEs as the next step in the assessment process. At the conclusion of the pilot, the findings and feasibility of a broader roll out will be considered.

    More information about the pilot, 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 1000 Tax Performance program as well as other initiatives, such as our Advanced Pricing Arrangement (APA) and advice and guidance programs to provide tax certainty to MNEs.

    For more information about the ATO’s involvement in ICAP please contact

      Last modified: 27 Apr 2018QC 55206