Arcotia Hatsidimitris - International Tax Dialogue

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40 – 4. GOVERNANCE ARRANGEMENTS • Resource planning: details of the team and the anticipated requirement for specialists/experts – internal and external • Process and timetable: for detailed fact-finding, obtaining information and supporting documentation and interim analysis • Process and timetable: for detailed review of findings, development of arguments and exchange of views with business and reaching decision point Each stage of the audit or enquiry should have a clear timetable and an expected completion date. These include the date by which the tax administration will take the decision not to seek any further information and will proceed to form a view on the basis of the information it already has, the date by which the tax administration will prepare a resolution review and finally the planned date of settlement. Such action plans usually operate as living documents and scoping and timelines are updated as the case progresses but at all times act to help maintain momentum in a case. The most effective action plans are those that are drawn up and agreed jointly by both the tax administration and the business and their advisors so that all are tied into the process. Even where tax administrations are unable to agree their plan with the taxpayer, they still find it useful to share the plan and the timetable, informing the business how and when, if necessary, they plan to use their information powers to force co-operation. Whatever the level of engagement with, or co-operation by, the business a project management approach to the management of cases is considered by tax administrations, business and their advisors to help to maintain progress. Key thoughts for the chapter Good governance arrangements ensure that the right issues are picked up for audit or enquiry and that senior manager have appropriate oversight to ensure the progress of cases. Robust and transparent governance arrangements also provide assurance to business that there is consistency of approach in transfer pricing cases. DEALING EFFECTIVELY WITH THE CHALLENGES OF TRANSFER PRICING © OECD 2012
5. MAINTAINING PROGRESS, TACKLING DELAY – 41 Chapter 5 Maintaining progress, tackling delay This chapter analyses the principal causes of delay in transfer pricing audits and enquiries and how they can be overcome. It discusses the process of document examination and how large volumes of material can best be managed. The chapter includes a discussion of the importance of good communication between tax administrations and taxpayers and the role of advisors. It also considers what use can be made of alternative dispute resolution techniques. DEALING EFFECTIVELY WITH THE CHALLENGES OF TRANSFER PRICING © OECD 2012
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ITD Transfer Pricing Conference: Tr
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Dealing Effectively with the Challe
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5 a) Organizational set-up Challeng
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5 a) Organizational set-up Head Off
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5 a) Reorganisation in the future H
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5 a) Organizational set-up National
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5 b) Staffing, training and managin
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Page 25 and 26: THANK YOU marica.houska@porezna-upr
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ANNEX D - 101 Annex D: Transfer pri
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ANNEX D - 103 • The approach from
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ORGANISATION FOR ECONOMIC CO-OPERAT
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Arcotia Hatsidimitris - International Tax Dialogue

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