Written by Richard Cornelisse
A new trend: open dialogue between revenue bodies, taxpayers and tax intermediaries
The new trend is to have an open dialogue between revenue bodies, taxpayers and tax intermediaries. OECD promotes ‘enhanced relationship’ (OECD report: Study into the Role of Tax Intermediaries ). Even if the authorities have not embraced such an approach (yet), a proactive mode and using elements of this way of working might not only safe time and money but also result in a good relationship.
A Guide on Compliance Risk Management for tax administrations has been developed as an update to the 2006 Risk Management Guide. It was made by tax officials for tax officials, both policy makers and operational staff. It is the outcome of work undertaken by the Fiscalis Risk Management Platform group since 2008.
A Guide on Risk Management for tax administrations has been developed in order to provide a common foundation for decisions at all management levels within tax administrations. The guide has been prepared by tax officials for tax officials. It is the outcome of work undertaken by a Fiscalis Risk Analysis Project team since 2004.
Horizontal Monitoring in the Netherlands
Senior Accounting Officer Guidance - UK
Where possible, HMRC relies on large companies’ own governance, systems and processes to manage risks to tax compliance. As part of the Business Risk Review a CRM evaluates how the group’s approach to these factors mitigates the inherent risks to tax compliance within the group.The Senior Accounting Officer (SAO) provisions fully fit with this approach.
The provisions make the SAO of a qualifying company responsible for ensuring that the company establishes and maintains appropriate tax accounting arrangements that allow the tax liabilities of the company to be calculated accurately in all material respects.
The Australian Tax Office (ATO)
Australia's proactive efforts to change the international tax arena. This practice statement is a draft for consultation purposes only. When the final practice statement issues, it will have the following preamble: This practice statement is an internal ATO document, and is an instruction to ATO staff.
Taxpayers can rely on this practice statement to provide them with protection from interest and penalties in the following way. If a statement turns out to be incorrect and taxpayers underpay their tax as a result, they will not have to pay a penalty. Nor will they have to pay interest on the underpayment provided they reasonably relied on this practice statement in good faith. However, even if they don't have to pay a penalty or interest, taxpayers will have to pay the correct amount of tax provided the time limits under the law allow it.
This practice statement is designed to assist Tax officers who are contemplating the application of Part IVA or other GAARs to an arrangement, including in a private ruling, Public Ruling (including a Product Ruling or a Class Ruling) or other document setting out the ATO view.
See chapter: Australian Taxation Office (ATO)
Singapore - Enhanced Taxpayer Relationship (ETR)
The Enhanced Taxpayer Relationship (ETR) Programme was introduced in 2008 as a service initiative and aims to build an open and collaborative taxpayer relationship through regular engagement with large companies, mutually benefitting IRAS and these companies.
See chapter Singapore - ETR
OECD Tax Administration 2015
Tax Administration 2015, produced under the auspices of the Forum on Tax Administration, is a unique and comprehensive survey of tax administration systems, practices and performance across 56 advanced and emerging economies (including all OECD, EU, and G20 members).
Its starting point is the premise that revenue bodies can be better informed and work more effectively together given a broad understanding of the administrative context in which each operates. However, its information content is also likely to be of interest to many external parties (e.g. academics, external audit agencies, regional tax bodies, and international bodies providing technical assistance).
The series identifies some of the fundamental elements of national tax system administration and uses data, analyses and country examples to identify key trends, comparative levels of performance, recent and planned developments, and good practices.
- UK - Improving Large Business Compliance
- OECD's - BEPS 2015 Final Reports
- BEPS – Country by Country report also implemented in the Netherlands
- Technical consultation: country-by-country reporting - UK
- The Australian Tax Office (ATO): Tax benefits/avoidance & GAAR
Benchmark survey on tax
The slide deck starts with a trend overview of the author and subsequently relevant tax survey findings were gathered that relate to these trends spotted.
The complete overview is relevant from a priotization and tax strategy perspective.
Written by Richard Cornelisse
I started my career as a manager at Arthur Andersen and then became a partner in EY where I led the indirect tax performance team for Netherlands and Belgium. Currently I am a senior managing director of Key Group.
I have over 20 years’ experience advising clients on international VAT issues. I am specialized in the tax aspects of financial transformations, shared service centre migration, and post merger integration work. I am also somewhat of a mentor, giving back to the profession. If you are interested in conversation and discussion, please feel free to contact me.