OECD: Updated International Compliance Assurance Programme (ICAP) FAQs (December 2024)
Revised FAQs reflect favorable developments in the ICAP program
Share
December 5, 2024
The Organisation for Economic Cooperation and Development (OECD) in December 2024 published updated “frequently asked questions” (FAQs) on the International Compliance Assurance Programme (ICAP), a multilateral risk assessment program for transfer pricing and permanent establishment issues.
The FAQs follow the release earlier this year of ICAP statistics, which show that ICAP can be a powerful tool for preventing disputes.
The list of questions marked as “new” are:
4. What are the ICAP application deadlines?
5. What are the target timeframes for ICAP?
14. What is the MNE group’s role in determining the scope of an ICAP risk assessment?
KPMG observation
The revised FAQs reflect favorable developments in the ICAP program, including the elimination of biannual application deadlines in favor of rolling applications. The FAQs now clarify that taxpayers can request limited-scope ICAP consideration for specific segments, geographic areas, or functions, rather than requesting holistic consideration. However, a taxpayer requesting a limited ICAP scope must still submit a holistic documentation package.