KPMG report: Implications of ICAP statistics
ICAP statistics and implications for businesses looking to obtain tax certainty
The Organisation for Economic Cooperation and Development (OECD) three years ago launched the International Compliance Assurance Programme (ICAP) as a permanent multilateral risk assessment of a multinational enterprise (MNE) group’s key international tax risks.
ICAP involves a review of selected transfer pricing and permanent establishment (PE) issues, and while it cannot provide true certainty in the manner of an advance pricing agreement (APA), it is designed to provide comfort and, where needed and feasible, to facilitate issue resolution without the need for a separate competent authority (CA) procedure.
Until the official release of ICAP statistics in January 2024 (read TaxNewsFlash), taxpayers could assess ICAP only on the basis of sparse anecdotal evidence. The ICAP statistics sheds light on what was largely a black box and allows taxpayers to make informed choices with regard to tax certainty.
Read a March 2024 report* [PDF 95 KB] prepared by KPMG LLP that discusses the ICAP statistics and their implications for businesses looking to obtain tax certainty.
* This article appears in International Tax Review and is provided with permission.