Tax administration

Study into the Role of Tax Intermediaries


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Publication Date: 8/04/2008
Pages: 90


Study into the Role of Tax Intermediaries


This report sets out the conclusions of the OECD Tax Intermediaries Study, that commenced in September 2006 following the Forum on Tax Administration’s (FTA) third meeting in Seoul, Korea.

The heads and deputy heads of revenue bodies who attended that meeting were unanimous in noting concerns about non-compliance with tax laws in an international context, in particular in relation to the spread of aggressive tax planning marketed by some tax intermediaries (e.g. law and accounting firms, other tax advisors and financial institutions).

The mandate to the study team was therefore to improve understanding of the role tax intermediaries play in the operation of tax systems and specifically to understand their role in “unacceptable tax minimisation arrangements”. In addition, the study team was to identify strategies for strengthening the relationship between tax intermediaries and revenue bodies.

The report concludes that to understand the role of tax intermediaries and, more importantly, to influence their behaviour, revenue bodies need to take a broader approach.  Tax intermediaries are the supply side of a relationship in which taxpayers, their clients, form the demand side.  This is a tripartite relationship in which revenue bodies are the other party.  Therefore, the report explores strategies to improve the relationships between revenue bodies and large corporate taxpayers.

The report also concludes that risk management is an important tool enabling revenue bodies to prioritise risk and allocate resources effectively.  It identifies strategies to directly address the risks posed by taxpayers and tax intermediaries engaged in aggressive tax planning.

Table of contents


Executive Summary
Chapter 1. Introduction
Chapter 2. The Seoul Declaration: A History, Context, and Framework for this Report
Chapter 3. The Tax Environment
Chapter 4. Responding to Tax Intermediaries Who Engage in Aggressive Tax Planning
Chapter 5. Risk Management
Chapter 6. The Need for Information
Chapter 7. Revenue Body Attributes
Chapter 8. The Enhanced Relationship
Chapter 9. Banks
Chapter 10. Conclusions and Recommendations
Annex 4.1. Background
Annex 4.2. USA - Office of Professional Responsibility (OPR) and Circular 230
Annex 4.3. USA - Future Compliance Agreements
Annex 6.1. USA - Reportable Transactions
Annex 6.2. UK - Disclosure Regime
Annex 7.1. Achieving Commercial Awareness
Annex 7.2. The Impartial Approach
Annex 8.1. Ireland - The Cooperative Approach to Tax Compliance

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Fourth OECD Forum on Tax Administration: Cape Town Communique

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