1. Organisation for Economic Co-operation and Development
MULTILATERAL TAX NETWORK
Auditing Multinational
Enterprises,
International Tax
Avoidance and Evasion
1Ankara, 7-11 May 2007
- Introduction
1 - Opening and Introduction
1
Centre for Tax Policy and Administration

2. Welcome
 Introductions
 Event Structure
 Domestic Arrangements and
timings (flexible approach)
 Purpose and Objectives
 An overview of the OECD
2

3. Event structure
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
3
New ‘advanced’ event
Plan for the week:
• Preliminary look at features of MNEs
• Overview of the taxation of MNE profit
• An extended case study spanning the week, looking at:
- Practical aspects of auditing
- Typical tax planning techniques
- Transfer pricing – main principles and case study on methods
- The ownership and use of intellectual property
- Permanent Establishments
- Controlled Foreign Companies
- Resolving disputes
Review and wrap up
•

4. Objectives of the event
 Share experiences on specific international
issues
 Develop an understanding of issues concerning
the taxation of multinational enterprises
 Discuss detection and audit techniques
4

5. The OECD
 Membership: 3 NAFTA, 4 Asian-Pacific countries and 23
European countries
Setter of “soft” and occasionally “hard” rules
A forum for discussing the economic and social challenges
of interdependence and globalisation
A provider of comparative data, analysis and forecasts to
underpin multilateral co-operation


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5

6. The Committee on Fiscal Affairs
What are we?
What do we cover?
How are we organised?
6
A forum for senior policy makers and
administrators
All international and related domestic tax issues
• Biannual meeting
• Eight subsidiary bodies
• Centre for Tax Policy and Administration

7. The Committee on Fiscal Affairs
Subsidiary Body*
Area of responsibility
Working Party N°1
Tax Conventions and Related Questions
Working Party N°2
Tax Policy Analysis and Tax Statistics
Working Party N°6
Taxation of Multinational Enterprises
Working Party N°8
Tax Avoidance and Evasion
Working Party N°9
Consumption Taxes
Forum on Harmful Tax Practices
Addresses anti-competitive tax practices and
is working with tax havens to improve
transparency and to establish effective
exchange of information
Forum on Tax Administration
Focuses on taxpayer service and compliance
Board for Co-operation with Non-OECD
Economies
Has the responsibility of supervising the
alignment between the co-operation
programmes with NOEs and the core
interests and expertise of the CFA
7
* Working Parties N° 3, 4, 5, 7 were abolished

8. Major outputs of the CFA
 Model Tax Convention
 Transfer Pricing Guidelines
 Standards on Exchange of Information
 Best Practices Guidelines in Tax Administration
 International VAT/GST Guidelines
 Comparative Analysis and Statistics on Tax Levels
and Structures
 Anti-Bribery Convention
8

9. Limited Membership, Global Reach
Why involve Non-OECD
economies?
How ?
Outcomes
9
• Global guidelines need global acceptance
• To assist in the development of their tax
systems
• Observers
• Developing partnerships
• Multilateral, regional and in-country
programmes
•31 NOEs set out position on
Model
•Most NOEs basing transfer pricing
legislation on OECD Guidelines
• A more coherent global tax environment
for MNEs

10. Limited Membership, Global Reach
Why involve Non-OECD
economies?
How ?
Outcomes
9
• Global guidelines need global acceptance
• To assist in the development of their tax
systems
• Observers
• Developing partnerships
• Multilateral, regional and in-country
programmes
•31 NOEs set out position on
Model
•Most NOEs basing transfer pricing
legislation on OECD Guidelines
• A more coherent global tax environment
for MNEs