Tax Security Day brought together more than 200 tax policy makers, tax administrations, business representatives and other stakeholders from more than 50 countries. They took stock of the status of the tax security program and discussed ways to further improve dispute resolution and dispute resolution. Discussions focused on all tax instruments available to tax administrations, including cooperative compliance programmes, pre-jurisdiction agreements, the International Compliance Assurance Programme (ICAP), joint audit and the cartel procedure (MAP). On Tax Security Day, France also joined the ICAP pilot project, bringing the total number of tax administrations participating in the ICAP pilot project to 18. The meeting highlighted the relevance of the oecd`s recent report on tax morale. The report examines the latest information on the importance of tax security as a determinant of companies` willingness to participate positively in the tax system, particularly in developing countries. The annex begins with the definition of the different types of ABS and defines the objectives of the APP process. The suitability for conclusion of a POP-APA is examined with regard to contractual matters and other factors such as the examination status of the taxable person. Issues relating to multilateral SAAs (i.e. where there is more than one bilateral agreement) will also be discussed.

The core of the Annex deals in detail with the whole POP-ABS process, starting with the meetings preceding the submission of a proposal, its evaluation by the tax authorities, the discussion and conclusion of the mutual agreement, the implementation of this mutual agreement and, finally, the follow-up of the agreement and a possible extension.