By co-ordinating conversations between an MNE group and multiple tax administrations, ICAP supports the effective use of transfer pricing documentation, including the MNE group’s Country-by-Country report, providing a faster, clearer and more efficient route to improved multilateral tax certainty. ICAP should reduce the resource burden on both MNE groups and tax administrations, meaning fewer disputes requiring resolution through mutual agreement proceedings. Where an area is identified as needing further attention, work conducted in ICAP can improve the efficiency of compliance action taken outside the programme, if needed.
OECD International Compliance Assurance Programme
ICAP is a voluntary risk assessment and assurance programme to facilitate open and co-operative multilateral engagements between MNE groups willing to engage actively and transparently and tax administrations in jurisdictions where they have activities.
About
Key documents
ICAP Statistics
The International Compliance Assurance Programme: Aggregated results and statistics were released on 29 January 2024. These statistics cover all ICAP cases completed by October 2023, including the two ICAP pilots, and provide an overview of the jurisdictions and topics covered by the completed risk assessments, the time taken to complete a risk assessment, and aggregated data on risk assessment outcomes. They also consider the relationship between ICAP and other routes to tax certainty such as advance pricing arrangements (APAs) and mutual agreement procedures (MAPs), including how these tools complement each other and can be used together by an MNE group to manage its tax risk and increase tax certainty.
ICAP Documentation Requirements (NEW)
The ICAP documentation package includes two parts: the Selection Documentation Package, which is provided at the time of applying to ICAP, and the Main Documentation Package, which is provided before the risk assessment commences. During the risk assessment, some supplementary documentation may be requested by tax administrations. Following the completion of the risk assessment, each Covered Tax Administration will issue an Outcome Letter.
The following high-level information is expected to be provided during the selection stage:
Coming soon
Coming soon
ICAP Handbook
The International Compliance Assurance Programme: Handbook for tax administrations and MNE groups contains information on the process for ICAP reflecting the experience and feedback of tax administrations and MNE groups that participated in two pilots for the programme, commencing in 2018 and 2019. The handbook includes a detailed description of each stage of the ICAP process, the documentation and information an MNE group participating in ICAP will provide, the level of comfort they may achieve as a result of participation in the programme, and a comparison of ICAP with other possible routes to greater tax certainty.
Information on Participating Tax Administrations
The International Compliance Assurance Programme: Information on Participating Tax Administrations provides up to date information regarding each of the tax administrations participating in the OECD Forum of Tax Administration (FTA) International Compliance Assurance Programme (ICAP). This document also includes a list of the contact details for each tax administration, which can be used to determine the correct contact person in the jurisdiction in which and MNE Group may with to apply to ICAP.
Participating tax administrations
The tax administrations participating in ICAP are listed below with, where available, a link to the dedicated page on their website. This list will be updated as further tax administrations confirm participation in the programme.
Application dates
The next three deadlines for submission of an application to participate in ICAP are 30 September 2024, 31 March 2025 and 30 September 2025. Future deadlines will be released in due course.
MNE groups that wish to discuss possible participation in ICAP should contact the tax administration in the jurisdiction where their ultimate parent entity is resident in advance of the next application deadline of 30 September 2024.
Relevant contact details can be found in this database (.pdf). General queries can be addressed to icap@oecd.org.
Awareness sessions
In March and April 2021, the OECD held two awareness sessions for MNEs willing to learn more about the programme. Download the supporting presentation (PDF) used during these sessions.
FAQs
A list of frequently asked questions from MNE groups is available.
Find out more
Questions concerning the programme may be directed to icap@oecd.org.