A review of Brazil approaches to cooperative compliance in light of International Tax Practice and the OECD concept

Cooperative tax compliance approaches were initiated in the 2000s as an alternative to more efficiently allocate tax administrations’ limited resources to high-risk taxpayers while establishing a more collaborative, transparent, and trust-based relationship with those that are low risk. In 2008 and 2013, the OECD began to promote ‘enhanced relationship’ approaches for which taxpayers would offer full transparency in exchange for less tax uncertainty. Since then, cooperative tax compliance has gained importance with an increasing number of countries adopting it and, in 2018, with the inauguration of an international and multilateral program, the International Compliance Assurance Programme. Despite that, there is not yet a uniform understanding of the constituting elements of cooperative compliance as countries with completely different approaches from one another all claim to have established cooperative compliance programs. In this article, the author reviews the approaches to cooperative tax compliance existing in Brazil, testing if such approaches conform with international tax practice and the OECD Cooperative Compliance Framework.