Theo Poolen

International Tax Review is part of Legal Benchmarking Limited, 4 Bouverie Street, London, EC4Y 8AX

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

Countries which care about fair taxation of tech multinationals and equitable global distribution of wealth should back the UN’s tax framework, writes economist Abdelmalek Riad
The cuts disproportionately affected staff in certain positions, the report also found; in other news, MHA announced the €24m acquisition of Baker Tilly South East Europe
The plan aims to improve the efficiency, transparency, and effectiveness of direct tax administration in India
Meanwhile, South Africa’s finance minister has accepted a court decision on suspending a VAT increase and US President Donald Trump mulls a 100% tariff on foreign films
Jaime Carey speaks about the benefits of his tax background, DEI values, the use of AI for a smarter legal practice, and other priorities that will define his presidency
Historically low levels of attrition over consecutive years made a ‘difficult decision’ necessary, PwC has reportedly said
WTS Global is also vetting new potential member firms in Algeria, Cote D’Ivoire and Benin, Kelly Mgbor tells ITR in an exclusive interview
The scope of qualifying pillar two tax credits could reportedly be broadened; in other news, hundreds of IRS appeals staff are to resign
For many taxpayers, the prospect of long-term certainty that a bilateral APA offers can override concerns about time, cost and confidentiality
Levine, who served under the Joe Biden administration, led the US’s negotiations on the OECD’s two-pillar solution
Gift this article