1. Improving domestic resources mobilisation Panel III Kenya / Nairobi 2019
Steffen W. Scholze

2. Organisation / Structure of involved administrations
Legal issues
Organisation / Structure of involved administrations
Tax Inspectors without Borders
Web links

3. preliminary remarks
The following comments relate to cooperation in tax matters
Criminal proceedings and money laundering are regulated completely differently in Germany with regard to the proceedings themselves and the responsibilities of the authorities involved.

4. Legal requirements for cooperation in Tax matters
Tax Treaties (Germany – African countries) (13)
Tax Treaties (Germany – African countries) under negotiation (7)
Convention on Mutual Administrative Assistance in Tax Matters OECD Model
Tax Information Exchange Agreements (TIEAs)

5. Global tax environment
The integration of national economies and markets has increased substantially in recent years

6. Legal Solutions in the past Solutions in advance
Solutions within the scope of an audit
Solutions in advance
advanced pricing agreements
Joint Audit
MAP/Arbitration procedures

7. MAP/Arbitration procedures
Take a long time
Avoid double taxation, no double non-taxation (application)
Not subject to legal action
Company does not participate in the process
Effect on the past
Two further assessment procedures will be necessary

8. APA
Very costly
Often no longer “advanced” due to long process duration

9. Simultaneous audits Joint Audits Simultaneous controls
Multi-Lateral controls

10. Forms of exchanging information
Joint Audit
Simultaneous controls
Presence of foreign officials
Exchange of information upon request
Spontaneous information
Automatic exchange of information

11. Benefits of coordinated (joint) audits
Prompt and complete, consensus based clarification of complex international facts
Avoidance of disputes –MAPs
In case of failure at least commonly determined facts

12. Organisation / Structure
Provided that TP legislation is in place, there is a need for trained auditors and persons to coordinate the process.
Germany attaches great importance to the Joint Audit instrument and is also prepared to provide assistance with pilot projects.

13. TIWB - Tax Inspectors without Borders
The Addis Tax Initiative (ATI) is a multi-stakeholder partnership of development partners and partner countries that aims to mobilise significant increases in domestic revenue and to improve the transparency, fairness, effectiveness and efficiency of tax systems in partner countries
TIWB is a joint initiative of the OECD and UNDP for delivering assistance needed to build tax audit capacity in developing countries, bridging the gap between theory and practice and complementing efforts from the international development community
Germany supports Jamaica within this framework since beginning 2017 until now with 7 missions

14. Aims and objectives
Support of the TP Team / Large Taxpayers offices / Administration in general
Case selection
Technical and legal support
Audit technique / soft skills

15. Starting point and first actions
Top 25 / 50 list of large companies
Audit preparations
Participation in field audits / visits
meetings
prioritisation

16. additional keywords Taxation of online transactions (E-Commerce)
Taxation of wealth millionaires (HNWI - High-Net-Worth-Individuals) including Sportsmen , Artists, etc.
complete audit of companies with all business lines
Taxation of mining industry, telecommunication industry and financial service providers
more cooperation in the region as an example such as “Nordic” convention or CARICOM
Balance - as far as possible – for inbound / outbound cases
holy cows?

17. Web links @ https://www.bzst.de/EN/Home/home_node.html

18. Imprint
Thank you !
Contact Federal Central Tax Office An der Küppe Bonn Contact person: Steffen W. Scholze Tel: +49 (0) – 2314 Mobil: