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.
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.
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.
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.
Tax Administrations participating in ICAP
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.
In addition to the ICAP Handbook, further information on the tax administrations participating in ICAP can be found in this database (.xlsx). Questions concerning the programme may also be directed to [email protected].
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.
The next three deadlines for submission of an application to participate in ICAP are 31 March 2024, 30 September 2024, and 31 March 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 31 March 2024.
A list of frequently asked questions from MNE groups is available.
Find out more about the OECD work on: