Tax Risk Management Between Tax Authorities and Large Companies: The Cooperative Compliance Regime

Abstract

Based on the reinforced relations between Tax Authorities and taxpayers as suggested by the OECD, the tax law has introduced the cooperative compliance regime, marking the passage from the ex post control of income tax returns to the ex ante cooperative dialogue on the tax base. Under this regime, the relations between tax authorities and large companies are based on a preliminary dialogue to settle interpretative disputes over income tax returns before the taxpayer submits his tax return. The purpose is to guarantee large companies a considerable reduction in the risk of ex post assessment, tax disputes and penalizing consequences and to favor the spontaneous emergence of the taxable base. However, this work examines the numerous criticisms of the cooperative compliance regime that may hamper the success of this scheme.