On January 23, 2018, the International Compliance Assurance Programme (ICAP) was launched at an orientation event in Washington, DC. The ICAP pilot is a voluntary program in which the participants will use country-by-country reporting and other information to establish multilateral agreements in order to establish early tax certainty and assurance. The ICAP handbook can be found here.
The pilot program includes eight Organisation for Economic Co-operation Development (OECD) Forum on Tax Administration (FTA) member tax administrations and eight multinational entities (one headquartered in each of the eight countries including: Australia, Canada, Italy, Japan, the Netherlands, Spain, the United Kingdom and the United States). Under the program, the participant will engage with several jurisdictions at once in order to efficiently establish and address the specific international tax risks posed by its transfer pricing and permanent establishments. The tax administrations will jointly review the information supplied by the participant and will coordinate any follow-up questions. The participant can then engage with the tax administrations simultaneously, preventing the need for multiple APAs and resulting in fewer disputes.