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International review for February 2024

Tim Sarson (KPMG) reports on recent developments that matter from around the globe, in a rare month of respite from BEPS 2.0.

OECD update

On 29 January 2024 the OECD released the first aggregated statistics from the International Compliance Assurance Programme (ICAP). ICAP is a voluntary risk assessment and assurance programme to facilitate open and co-operative multilateral engagements between MNE groups and tax administrations in jurisdictions where they have activities.

The process supports the effective use of transfer pricing documentation including the MNE’s Country-by-Country report providing a more efficient route to improved multilateral tax certainty. ICAP should reduce the resource burden for businesses and tax administrations meaning fewer disputes requiring resolution through mutual agreement proceedings.

The statistics cover all cases completed by October 2023 including the two ICAP pilots and provide an overview of the jurisdictions and topics covered by the completed risk assessments ...

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