OECD COVID-19 TPG paragraph 112

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A range of technological solutions are available to replace and/or complement, traditional methods of communication, such as face-to-face meetings and the exchange of physical documentation, while maintaining confidentiality and security requirements. There may be situations where flexible approaches are not readily identifiable or appropriate, however, tax administrations and taxpayers should be encouraged to assess alternative approaches to maintaining progress in APA discussions on a case-by- case basis rather than defaulting to historic working methods or one-size fits all solutions. Effective use of tax administration and taxpayer resources is crucial during the period of the COVID-19 pandemic and practical experience suggests that the following have been utilised with success in certain cases:

    • Virtual tax administration and taxpayer case conferences in the place of physical meetings (for example, telephone and video conferences)
    • Virtual functional interviews with taxpayer’s employees
    • Virtual taxpayer site visits in the place of physical visits (so long as the performance of adequate due diligence is not compromised)
    • Electronic documentation sharing (via encrypted emails or electronic sharing platforms).

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