Approaches to Cooperative Compliance in the BRIC countries and in international programs: Identifying, reviewing and testing elements and approaches to Cooperative Compliance in the BRIC countries and in international programs

This thesis investigated whether Cooperative Compliance approaches, which foster a trust-based, transparent and cooperative relationship between taxpayers and tax administrations, can be identified in the BRIC countries (Brazil, Russia, India, and China) and in two international and multilateral programmes (the International Compliance Assurance Programme (ICAP) and the European Trust and Cooperation Approach (ETACA)).
The research was inspired by the observation that the BRIC countries informed in the OECD questionnaires, covering years 2015–2019, that Cooperative Compliance existed, or was under implementation, in their jurisdictions, an information that contrasted with the author’s professional experience in those countries and raised questions about what specific practices were being referred to as Cooperative Compliance by the BRIC countries and whether these practices aligned with the experiences of the pioneer countries, the OECD concept and the theoretical framework of Cooperative Compliance.
Given the absence of a commonly accepted definition of Cooperative Compliance, the initial sections of the thesis were dedicated to reviewing the theoretical framework that supported the emergence of Cooperative Compliance; to describe the original motivators, objectives and elements of Cooperative Compliance in the pioneer countries; to establish a definition of Cooperative Compliance to be used in the research; to assess the relationship approaches that the BRIC countries claimed to be Cooperative Compliance; to verify if the approaches implemented in two international programs also conformed with the definition of Cooperative Compliance.
The findings of the research contribute to a deeper understanding of how Cooperative Compliance is conceptualised across diverse tax administrations, revealing significant variation in interpretation, scope, and implementation. The thesis ultimately clarifies which elements can be considered essential to Cooperative Compliance and assesses the extent to which the BRIC jurisdictions and the two international programs adhere to these elements. This provides an informed basis for evaluating the coherence, credibility, and future development of Cooperative Compliance globally.