International Tax Review is part of the Delinian Group, Delinian Limited, 8 Bouverie Street, London, EC4Y 8AX, Registered in England & Wales, Company number 00954730
Copyright © Delinian Limited and its affiliated companies 2023

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 & bottom lb ros

More from across our site

David Pickstone and Anastasia Nourescu of Stewarts review the facts and implications of Ørsted’s appeal at the Upper Tribunal.
The Internal Revenue Service will lose the funding as part of the US debt limit deal, while Amazon UK reaps the benefits of the 130% ‘super-deduction’.
The European Commission wanted to make an example of US companies like Apple, but its crusade against ‘sweetheart’ tax rulings may be derailed at the CJEU.
The OECD has announced that a TP training programme is about to conclude in West Africa, a region that has been plagued by mispricing activities for a number of years.
Richard Murphy and Andrew Baker make the case for tax transparency as a public good and how key principles should lead to a better tax system.
‘Go on leave, effective immediately’, PwC has told nine partners in the latest development in the firm’s ongoing tax scandal.
The forum heard that VAT professionals are struggling under new pressures to validate transactions and catch fraud, responsibilities that they say should lie with governments.
The working paper suggested a new framework for boosting effective carbon rates and reducing the inconsistency of climate policy.
UAE firm Virtuzone launches ‘TaxGPT’, claiming it is the first AI-powered tax tool, while the Australian police faces claims of a conflict of interest over its PwC audit contract.
The US technology company is defending its past Irish tax arrangements at the CJEU in a final showdown that could have major political repercussions.