1. Cooperative Compliance-Breaking the Barriers
Adapting the model to address the challenges facing developing countries

2. A reminder of the history
From enhanced relationship to cooperative compliance
The importance of governance in the context of increasing political concern about the behaviour of big corporates nd the emergence of the BEPS project
Injecting rigor into the concept: justified trust and the central part that tax control frameworks have to play
So, does the concept continue to have legitimacy in a post BEPS world?

3. Just when you thought it was safe…....

4. BEPS-the pressure is on to implement….
Tax administrations ready to act on “Panama Papers”
08/04/ Government officials from around the world have called on the OECD to convene a special project meeting of  the Joint International Tax Shelter Information and Collaboration (JITSIC) Network to explore possibilities of co-operation and information-sharing, identify tax compliance risks and agree collaborative  action, in light of the “Panama Papers” revelations. 
The meeting, to be held in Paris on Wednesday 13 April, will bring together senior tax administration officials from countries worldwide.

5. And Developing Countries face particular challenges
BEPS implementation requires action on several fronts:
Policy
International agreements
Domestic law reform in complex areas – transfer pricing, interest deductibility, hybrids….
Operational
Creating or building a large taxpayer function
Making use of the new transfer pricing documentation and country by country reports
Developing the capability within the tax administration which goes beyond tax technical knowledge to include commercial and economic understanding
And finding a way to keep good people as they acquire valuable and highly marketable skills.

6. Where does cooperative compliance fit in?
Addressing the capability challenge
Allowing tax administration staff to obtain insights into the operations of MNEs, the way they organize and plan, which are hard to come by in a relationship characterized by conflict and “hide and seek”.
Requires a holistic approach to the taxation of entities owned by the same MNE
Helps to develop a risk driven approach to compliance management
Freeing up resources
Encouraging FDI and boosting tax morale.

7. The essential features of the model
For the Tax administration:
Commercial Awareness
Impartiality
Proportionality
Openness and transparency
Responsiveness
Governance
Strategic Fit
For the Taxpayer
Disclosure and transparency underpinned by a robust tax control framework

8. Putting the theory to the test-
The role of the pilots
Putting the theory to the test-
can the cooperative compliance model deliver on its promise to help developing countries in their mobilisation against BEPS?

9. INSTITUTE FOR AUSTRIAN AND INTERNATIONAL TAX LAW
Welthandelsplatz 1, 1020 Vienna, Austria
Jonathan Leigh Pemberton T F