This article provides an overview of Italy's new cooperative compliance regime from a business perspective, focusing on the obligations of corporate taxpayers wishing to exploit cooperative compliance, engagement requirements, and benefits to be gained.
This Technical Assistance Report discusses measures to enhance the effectiveness of tax administration system in Italy. The Italian tax administration system comprises multiple entities, which demands tight coordination. Tax revenues are high, but collection performance in the main taxes is mixed. The agencies’ accountability framework to the Ministry of Economy and Finance is very detailed and should be more strategic. The agencies have not been empowered to develop their own medium-term strategic plan. A holistic approach to managing risks to the tax system is needed, including targeted compliance strategies. The accumulation of tax debts is alarming, and structural issues need to be addressed urgently.
Prominent among initiatives addressing the urgent need for a common understanding between multinational enterprises (MNEs) and national tax authorities about risks and risk assessment is the International Compliance Assurance Programme (ICAP), which provides a channel for MNEs to engage in simultaneous discussions with multiple national tax administrations, thus enhancing the potential for advance tax assurance. To a certain extent, the ICAP represents the internationalization of Co-operative Compliance frameworks which were, until then, restricted within the borders of single jurisdictions. This book is the first to investigate Co-operative Compliance alongside with the ICAP, describing developments in twelve countries (Australia, Austria, Canada, Germany, Italy, Japan, the Netherlands, Norway, Poland, Spain, the United Kingdom, and the United States). Following a general introduction, two opening perspectives on the ICAP are presented, one from the OECD and one from a participating tax administration (the Netherlands), leading to the twelve country reports and a special chapter on transfer pricing, which is the main issue in international tax disputes. Specific elements reviewed include the following: criteria to enter the programme; the range of taxes covered by the programme; real-time consultation procedures; appeal procedures within the programme; the possibility to ‘agree to disagree’ and to continue Co-operative Compliance even in cases of litigation; risk management strategies within tax authorities; corporate administrative compliance burden; and main sources of tax uncertainty. Country reports are contributed by tax professionals and tax academics experienced in dealing with Co-operative Compliance and the ICAP. Each report addresses the same questions, so that all the reports cover the same features of domestic relationship approaches and the ICAP. A final chapter reviews the collected contributions and offers some concluding remarks. Although the ICAP process probably will undergo further adjustments, it is certain that the road to more international cooperation between tax authorities and MNEs is now open. This timely book, as a comparative review of the implementation of the ICAP among leading jurisdictions active in global trade, provides matchless insights into trends, similarities, differences and their implications. It will be welcomed by all stakeholders in the international tax community, including lawyers, taxation authorities and academics.
This report is the ninth edition of the OECD's Tax Administration Series. It provides internationally comparative data on aspects of tax systems and their administration in 59 advanced and emerging economies.
With contributions presented during the Second International Risk Management Conference, this first volume addresses important areas of risk management from a variety of angles and perspectives. The book will cover three separate tracks, including: legal issues in risk management, risk management in the public sector and in healthcare, and environmental risk management, and will be of interest to academic researchers and students in risk management, banking, and finance.
Businesses now operate amid a welter of risks that exist at various levels, both inside companies and at the network level. This handbook provides the latest integrated managerial approaches that help protect businesses from adverse events and their effects.
This report examines the relationship between large business taxpayers and revenue bodies, five years on from the publication of the FTA’s Study into the Role of Tax Intermediaries.
After describing the size of corporate tax losses and the policy issues related to their tax treatment, this report identifies three key risk areas in relation to use of losses for tax purposes: corporate reorganisations, financial instruments and non-arm’s length transfer pricing.
This book examines recent developments and high-profile debates that have arisen in the field of international tax law and European tax law. Topics such as international tax avoidance, corporate social responsibility, good governance in tax matters, harmful tax competition, state aid, tax treaty abuse and the financial transaction tax are considered. The OECD/G20 project on Base Erosion and Profit Shifting (BEPS) features prominently in the book. The interaction with the European Union's Action Plan to strengthen the fight against tax fraud and tax evasion is also considered. Particular attention is paid to specific BEPS deliverables, exploring them through the prism of European Union law. Can the two approaches be aligned or are there inherent conflicts between them? The book also explores whether, when it comes to aggressive tax planning, there are internal conflicts between the established case law of the Court of Justice and the emerging policy of the European institutions. By so doing it offers a review of issues which are of constitutional importance to the European Union. Finally, the book reflects on the future of international and European tax law in the post-BEPS world.
The concept of tax compliance is as old as the tax itself, but staying compliant with tax regulations has become increasingly demanding. A changing tax regulatory environment, resulting from regulatory actions of the OECD, the European Union and national governments, poses many problems for tax compliance awareness. This book explores various approaches to improving tax compliance. Starting with the procedures and processes that are at the centre of the debate, it includes the level of tax position security obtained as a result of cooperation between tax administration and an organisation, ending with tax compliance requirements imposed by one-sided action of tax administration. Offering an experience and evidence-based analysis of how tax compliance influences an organisation’s tax and financial position, the issues are examined from both a theoretical and a practical perspective, using empirical research and case studies with an international dimension for illustration. Emphasising a holistic approach to tax compliance and its role in tax risk management within an organisation, this study offers a framework for making the challenging task of tax compliance and risk management more effective and more efficient. Exploring tax compliance focusing on the tax world after the BEPS project and anti-tax evasion and anti-tax avoidance regulatory actions undertaken by the European Union and OECD, the book has a practical focus on tax system design within the organisation and will be of interest to students, researchers and practitioners working in the areas of tax law and tax compliance.