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Finding consensus: BEPS 2 0 and tax certainty
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TP and blocked income: The US approach
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US: Approach to TP and blocked income
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Despite its challenges, COVID-19 seems likely to leave a highly positive legacy for TP dispute prevention
The annual report of APA statistics by the advance pricing and mutual agreement programme (APMA) is a sort of bellwether for the US APA programme and for transfer pricing (TP) dispute prevention more generally. 2018’s statistics revealed an unprecedented surge in applications, driven in part by US tax reform and in part by an increase in the cost of APAs. 2019, by contrast, was a respectable but largely undistinguished year, reflecting good progress with cases closed without breaking any records.
The 2020 statistics are also, by and large, unremarkable – which, coming in the midst of a remarkably chaotic year, is a milestone accomplishment. In an article on last year’s statistics, we speculated that the COVID-19 pandemic might deter interested taxpayers from seeking APAs, and that pandemic-related disruptions could lead to APA cancellations in some cases. Neither possibil
ICAP offers some benefits that MAP and APAs cannot
February 2021 saw the publication of the OECD Forum on Tax Administration’s handbook on the International Compliance Assurance Programme (ICAP) and the launch of ICAP as a full-fledged, permanent dispute prevention programme.
ICAP provides a framework for multilateral risk assessment, allowing a multinational enterprise (MNE) to present its transfer pricing (TP), permanent establishment, and other international tax positions to a number of participating tax administrations.
ICAP was first explored during two rounds of pilot programmes. The initial 2017 pilot involved eight tax administrations, while 19 participated in the 2019 ‘ICAP 2.0’ pilot. It is a voluntary programme that is open by application; MNEs interested in potentially participating are invited to confer with the tax authority of the jurisdiction where their ultimate parent entity resides prior to the next application deadline of September 30 2021. Participat