Cooperative Compliance Program for Individuals and Trusts: A Proposal for a Compliance Passport

27 Pages Posted: 5 Nov 2020 Last revised: 30 Jun 2021

See all articles by Philip Marcovici

Philip Marcovici

affiliation not provided to SSRN

Noam Noked

The Chinese University of Hong Kong (CUHK) - Faculty of Law

Date Written: September 1, 2020

Abstract

Ensuring tax compliance among business and wealth owners is an important policy goal for many tax authorities. This article develops a proposal for a voluntary program for individuals, family trusts and private investment vehicles which draws upon existing cooperative compliance programs for large corporations, such as the OECD’s International Compliance Assurance Programme (ICAP). Under the proposed program, the authorities of the relevant jurisdictions would determine, on a joint basis, whether the participant is in full compliance with their tax obligations and whether there are any money laundering concerns. The implementation of this proposal could enhance a culture of cooperative compliance and free up enforcement resources. For participants, it could improve privacy, increase certainty, and reduce compliance costs and distortions. As this proposal has the potential to ensure compliance while reducing costs and risks for both tax authorities and taxpayers, it deserves serious consideration.

Keywords: Cooperative Compliance, ICAP, Trusts, High-Net-Worth Individuals, Tax Administration, AML

JEL Classification: K34

Suggested Citation

Marcovici, Philip and Noked, Noam, Cooperative Compliance Program for Individuals and Trusts: A Proposal for a Compliance Passport (September 1, 2020). 6 Journal of Tax Administration 33 (2021), The Chinese University of Hong Kong Faculty of Law Research Paper No. 2021-35, Available at SSRN: https://ssrn.com/abstract=3693571 or http://dx.doi.org/10.2139/ssrn.3693571

Philip Marcovici

affiliation not provided to SSRN

Noam Noked (Contact Author)

The Chinese University of Hong Kong (CUHK) - Faculty of Law ( email )

6/F, Lee Shau Kee Building
Shatin, New Territories
Hong Kong, Sha Tin
Hong Kong

HOME PAGE: http://www.law.cuhk.edu.hk/app/people/prof-noam-noked/

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