Theo Poolen

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Theo Poolen

Deputy director general, Dutch Tax and Customs

Theo Poolen

At least 24 countries have now implemented, or are moving to, a model of cooperative compliance, which is a collaborative way of working between large taxpayers and revenue authorities.

Collaborative working can save revenue authorities time, resources and money, while incentivising multinationals to be more transparent about their tax affairs and providing a more certain tax environment for companies.

The Netherlands is a world leader in the area of cooperative compliance, having introduced its formal cooperative compliance model, horizontal monitoring, in 2005.

Theo Poolen has been at the heart of the Dutch revenue authority’s implementation of cooperative compliance and is taking a lead role in helping the OECD promote the practice to its member countries.

Poolen became deputy director general of the Netherlands Tax and Customs Administration in 2004 and since 2005 has headed the development of the horizontal monitoring programme. He led the OECD and Forum on Tax Administration’s (FTA) report Co-operative Compliance: A framework, which he presented at the FTA’s meeting in Moscow in May.

As the number of countries implementing cooperative compliance grows, the next step, advocated by Poolen, is bilateral and multilateral cooperative compliance.

The Netherlands and the UK are piloting a bilateral arrangement with one large multinational that has substantial operations in both countries. It has been reported that the first results of that pilot were positive.

Cross-border arrangements on top of domestic arrangements, involving tax authorities in countries where a multinational has substantial operations, would seem to be ideal from an overall tax risk management perspective for the taxpayer, if they worked as well as local arrangements.

International double taxation would be avoided if there was agreement between the relevant tax authorities and the multinationals on tax risks and allocation of profit issues. From a cost perspective, in an ideal world, the taxpayer's compliance costs should be drastically reduced as information would have to be made available only once, and lengthy and costly procedures to resolve double tax and interpretation disputes would be avoided.

This instrument would also help tax authorities in their efforts in the context of the OECD base erosion and profit shifting (BEPS) project and would clearly fit in well with the public demand for more international cooperation between tax authorities to combat multinationals that are not paying their fair share of local tax.

The Global Tax 50 2013

« Previous

Rand Paul

View the complete list

Next »

Vladimir Putin

more across site & shared bottom lb ros

More from across our site

The Institute of Chartered Accountants in England and Wales also queried whether HMRC resources could be better spent scrutinising larger entities
Grant Thornton’s Austria tax head likens his practice to an escape room, shares his football coaching ambitions, and explains why tax is cool
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2025 EMEA Tax Awards
Awards
ITR is delighted to reveal all the shortlisted nominees for the 2025 Asia-Pacific Tax Awards
The fates of pillars one and two hang in the balance after the US successfully threw its weight around in G7 and Canadian negotiations
Rafael Tena tells ITR about the ‘crazy’ Mexican market, ditching the hourly rate, and refusing to grow his fledgling firm in an ‘unstructured way’
It should be easy for advisers to be transparent about costs, Brown Rudnick partner Matthew Sharp said in response to exclusive ITR in-house data
The sprawling legislation phases out Joe Biden-era green tax incentives for businesses; in other news, the UK will reportedly maintain its DST despite US pressure
New French legislation should create a more consistent legal environment for taxing gains from management packages, say Bruno Knadjian and Sylvain Piémont of Herbert Smith Freehills Kramer
The South Africa vs SC ruling may embolden the tax authority to take a more aggressive approach to TP assessments, an adviser tells ITR
Gift this article