ICAP – the OECD’s International Compliance Assurance Program – offers a way for multinational groups and tax authorities to collaborate, assess risk, and pursue certainty in the transfer pricing of Intercompany transactions. But how does the process unfold, and what can participants expect along the way?
This episode presents a unique opportunity to hear directly from both perspectives: Doug O’Donnell, former IRS Acting Commissioner and Deputy Commissioner, who was instrumental in shaping ICAP for tax administrations, and Erik Skarstad, who has navigated the program during his time as a Transfer Pricing leader for Fortune 100 companies. Their firsthand experiences reveal the practical realities, challenges and benefits of participating in ICAP.
Join host Brittany Hardin Tanguay as she welcomes Doug O’Donnell (Senior Managing Director, Washington National Tax – Tax Controversy & Dispute Resolution) and Erik Skarstad (Managing Director, Tax – Transfer Pricing) to unpack ICAP’s origins, objectives, and real-world impact. Together, they share insights from both sides of the table – government and taxpayer – on building trust, navigating challenges, and finding value in multinational cooperation.
KPMG Exploring Transfer Pricing: What is the International Compliance Assurance Program (video)
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September 3, 2025 | MAP Quest: A Conversation with Doug O'Donnell on Cross-Border Dispute Resolution
In this episode of Inside International Tax, we explore the Mutual Agreement Procedure (MAP) as a treaty-based process for resolving double taxation disputes between countries, focusing on how the MAP process operates at the IRS and internationally.
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