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New Multilateral Pilot Project for MNE Risk Assessment

New Multilateral Pilot Project for MNE Risk Assessment

A project created by Canada and other jurisdictions may improve international tax fairness.


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The International Tax Compliance Assurance Program (ICAP) was launched late January 2018. This pilot project is a voluntary program that hopes to improve communication between multinational enterprise groups and tax administrations to provide early tax certainty and assurance and ultimately reduce international tax disputes. Canada is joined by seven other jurisdictions in this project: Australia, Italy, Japan, the Netherlands, Spain, the U.S. and the UK.

This pilot project was developed under the framework of the OECD Forum on Tax Administration (FTA) Large Business and International Programme, which is sponsored by the CRA.

About ICAP

MNE risk assessments

The pilot is beginning with a multilateral assessment of the specific international tax risks posed by each multinational enterprise group (MNE group) in the pilot. This assessment will take place during the first half of 2018 and is expected to take a year to complete.

ICAP fundamentals

ICAP will use transfer pricing information (including information from a group's country-by-country report, master file and local file) to help co-ordinate conversations between multinational enterprise groups and tax administrations in different jurisdictions. In the long term, it hopes that this use of resources and communication will result in a more open and transparent tax environment, and ultimately fewer cases entering into mutual agreement proceedings (MAP)

For more information, contact your KPMG adviser.

Information is current to February 06, 2018. The information contained in this publication is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavour to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act upon such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's National Tax Centre at 416.777.8500

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