1. 1 International Tax Avoidance and Evasion 1 - Opening and Introduction Ankara, 7-11 May 2007 MULTILATERAL TAX NETWORK Auditing Multinational Enterprises, 1 - Introduction Centre for Tax Policy and Administration Organisation for Economic Co-operation and Development

2. 2 Welcome  Introductions  Event Structure  Domestic Arrangements and timings (flexible approach)  Purpose and Objectives  An overview of the OECD

3. Event structure  New ‘advanced’ event  Plan for the week: Preliminary look at features of MNEs Overview of the taxation of MNE profit An extended case study spanning the week, looking at: - Practical aspects of auditing - Typical tax planning techniques - Transfer pricing – main principles and case study on methods - The ownership and use of intellectual property - Permanent Establishments - Controlled Foreign Companies - Resolving disputes Review and wrap up 3

4. 4 Objectives of the event  Share experiences on specific international issues  Develop an understanding of issues concerning the taxation of multinational enterprises  Discuss detection and audit techniques

5. 5  Membership: 3 NAFTA, 4 Asian-Pacific countries and 23 European countries  Setter of “soft” and occasionally “hard” rules  A forum for discussing the economic and social challenges of interdependence and globalisation  A provider of comparative data, analysis and forecasts to underpin multilateral co-operation The OECD

6. 6 What are we? A forum for senior policy makers and administrators What do we cover? All international and related domestic tax issues Biannual meeting Eight subsidiary bodies Centre for Tax Policy and Administration How are we organised? The Committee on Fiscal Affairs

7. Subsidiary Body*Area of responsibility Working Party N°1Tax Conventions and Related Questions Working Party N°2Tax Policy Analysis and Tax Statistics Working Party N°6Taxation of Multinational Enterprises Working Party N°8Tax Avoidance and Evasion Working Party N°9Consumption Taxes Forum on Harmful Tax PracticesAddresses anti-competitive tax practices and is working with tax havens to improve transparency and to establish effective exchange of information Forum on Tax AdministrationFocuses on taxpayer service and compliance Board for Co-operation with Non-OECD Economies Has the responsibility of supervising the alignment between the co-operation programmes with NOEs and the core interests and expertise of the CFA 7 * Working Parties N° 3, 4, 5, 7 were abolished

8. Major outputs of the CFA  Model Tax Convention  Transfer Pricing Guidelines  Standards on Exchange of Information  Best Practices Guidelines in Tax Administration  International VAT/GST Guidelines  Comparative Analysis and Statistics on Tax Levels and Structures  Anti-Bribery Convention 8

9. 9 Limited Membership, Global Reach Why involve Non-OECD economies? Global guidelines need global acceptance To assist in the development of their tax systems How ? Observers Developing partnerships Multilateral, regional and in-country programmes Outcomes 31 NOEs set out position on Model Most NOEs basing transfer pricing legislation on OECD Guidelines A more coherent global tax environment for MNEs