Aggressive tax planning

Co-operation and exchange of information on ATP


The OECD provides a forum for countries to exchange information on tax planning schemes, detection methods and response strategies.  The ATP Expert Group is a sub-group of Working Party No. 11 that has responsibility for maintaining a secure directory of over 400 aggressive tax planning schemes submitted by member countries. 

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The ATP Directory is a secure database of aggressive tax planning schemes. Access to the database is limited to government officials from countries that are members of the Expert Group on the ATP Directory.  The Directory contains a database of more than 400 tax planning schemes and a section on hybrid mismatch arrangements with tables that compare the tax treatment of entities and instruments in various countries in order to facilitate the detection of hybrid mismatch arrangements.  

The purpose of the Directory is to allow government officials from member countries to share information on aggressive tax planning trends. Timely sharing of information on ATP schemes assists member states in understanding new tax planning techniques, facilitates their detection, enables countries to rapidly adapt their risk management strategies and to identify appropriate legislative and administrative responses.

A review undertaken by the Secretariat in 2012 showed that the information on the directory had assisted some countries to avoid substantial potential revenue loss (up to EUR 1.5 Billion) through the early identification of previously unknown ATP schemes.

The Directory is maintained by a sub-group of the members of Working Party No. 11 that adhere to certain confidentiality undertakings and agree to make an active contribution to the ATP directory. 

Directory data has formed the basis for 6 published reports that have been instrumental in contributing to the policy debate at an international level.  Recent projects include reports on corporate losses in the banking sector and beyond, on disclosure initiatives and on hybrid mismatch arrangements

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