Manual for the Control of International Tax Planning


"The CIAT Executive Secretariat presents the update of the Manual for the Control of International Tax Planning. This update has 42 sections, which were prepared in coordination with 48 experts who have extensive experience in tax administrations, ministries of finance, international organizations, academia, civil society and private initiatives.

The content includes an analysis of the various risks of tax evasion and avoidance, based on behaviours of multinational companies as detected by tax administrations from various countries, as well as the possible actions to identify said risks and consequently treat them. This material will be useful for all those interested in learning or strengthening their knowledge on these subjects, with a practice-based approach.

CIAT thanks all of those who generously contributed to make this initiative possible, and in particular, the GIZ (German Cooperation) and the EUROsociAL+ Program."

Manual for the Control of International Tax Planning

General Structure

1. Introduction, Scope, and Objective 4. Containment Measures for International Tax Planning 
2. International Tax Planning 4.1. General anti avoidance rules: domestic and international
3. Harmful International Tax Planning: Common Behaviours and Mechanisms to Identify Them 4.2. Specific anti avoidance rules: domestic and international
3.1. Thin-capitalization and other international financing operations 4.3. Anti-hybrid regimes
3.2. Transfer pricing manipulation 4.4. Ability to disregard or recharacterize transactions
3.3. Tax treaty abuse 4.5. Rules relating to international tax transparency
3.4. Abuse of domestic rules 4.6. Rules limiting tax base erosion through financial instruments
3.5. Hybrids 4.7. Transfer pricing regulations
3.6. Business restructuring 4.8. Anti tax haven rules
3.7. Tax residency 4.9. Measures to contain misconduct by promoters of tax planning schemes
3.8. Permanent establishments and commissionaire arrangements 4.10. Mechanisms to prevent abuse involving transactions of commodities and raw materials
3.9. Use of legal structures for concealment purposes, tax havens, and harmful tax regimes 4.11. Measures to contain avoidance or evasion by companies operating in the digital economy
3.10. Triangulation 4.12. Measures to contain the abuse of permanent establishments and commission agents
3.11. Transfer of intangibles 5. Tools for Combating International Tax Planning
3.12. Payments for technical assistance, royalties, interests, dividends, and service fees 5.1. Special information regimes, development and maintenance of databases: information obligations for taxpayers carrying out international operations
3.13. Leasing operations 5.2. Mechanisms to identify risks
3.14. Improper contractual allocation of risk 5.3. International cooperation
3.15. Artificial fragmentation of contracts 5.4. Initiatives regarding corporate responsibility and fiscal governance
3.16. Artificial generation of losses and artificial allocation of costs 5.5. Cooperative compliance initiatives as a preventative mechanism
3.17. Misuse of special purpose entities (also known as financial vehicle corporations) 5.6. Procedures to prevent abuse by companies operating in the digital economy
3.18. Profit shifting 5.7. Taxation of Cryptocurrencies
3.19. Tax compliance risks by companies operating in the digital economy 5.8. Advanced Pricing Agreements (APA)
  6. Other administrative issues
  6.1. Audit of multinational enterprises and entities with international operations

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