The relationship between the taxpayer and the authorities

Throughout this process, we expect tax authorities to leverage data, technology and digitalisation techniques to a maximum extent to increase the effectiveness of their data mining techniques and tax audits. Also, we expect to see an increase in the number of joint and even multilateral tax audits, where data from different domains and even different taxpayers will be used by multi-competency and -country audit teams.

Interestingly, the agreement also states that a ‘Charter’ or a ‘Code of Conduct’ will be implemented, clearly defining the rights and obligations of both the taxpayers and tax authorities during tax audits. Via this charter, the government intends to provide a framework to improve cooperation during tax audits. It remains to be seen which principles and rules will be included, but it would be good to see some other valuable concepts of cooperative compliance frameworks such as trust and legal certainty find their way to all taxpayers.