Tax Inspectors Without Borders, an OECD/UNDP joint initiative (TIWB)
The Tax Inspectors Without Borders (TIWB) Initiative aims to share tax audit knowledge and skills with tax administrations in developing countries through a targeted, real time "learning by doing" approach. Selected experts work with local tax officials directly on current audits and audit-related issues concerning international tax matters and general audit practices relevant for specific cases. This is a specialized area of tax audit assistance, given its focus on providing assistance on real, current cases. Assistance may be focused on pre-audit risk assessment and case selection, investigatory techniques, audit cases involving transfer pricing issues, anti-avoidance rules, or sector-specific issues.
For each TIWB audit assistance programme, the goal is to enhance capacity in the tax audit practice of the developing country tax administration (Host Administration). Through TIWB programmes, the Host Administration benefits by improving the quality and consistency of its audits, which in turn brings greater certainty and potentially more revenues for the Host Administration. Over the longer term, the overall investment climate is likely to improve and a culture of taxpayer compliance can be built through more effective enforcement. More broadly, the state-society relationship can be enhanced through greater engagement and confidence by taxpayers in the taxation process. This may lead ultimately to more effective and accountable governance. TIWB programmes complement existing tax-focused assistance programmes, to bring a practical approach to applying new knowledge.
TIWB is also extending its model of assistance to new areas: Tax Crime Investigations, Effective use of Automatically Exchanged Information, Tax Treaty Negotiation and Administration, Natural Resources and Environment Tax Issues. Pilot programmes are being rolled out in 2020-21.
Negotiation Support General
Global. Programmes currently underway in Africa, Asia and the Pacific, Eastern Europe and Latin America and the Caribbean.
Tax administrations use the TIWB Assistance Request Form to notify the TIWB Secretariat of its request. The Form communicates key information about the scope of the requested TIWB programme and the subjects it should covered. The Host Administration outlines the focus of the activities to be carried out during the TIWB programme and whether the activities will be audit-related, such as risk assessment and case selection, or will focus on applying new or different audit techniques to an audit team's daily practice, or will cover specific fiscal subjects, such as transfer pricing, thin capitalisation, etc. The Host Administration should ensure that the TIWB Assistance Request fits within the Host Administration's broader objectives and is adapted to its current capacities. This enables the Host Administration to identify the essential elements of the assistance it requires, and the results it wants to achieve.
Participation in a TIWB Programme, which involves a foreign national expert working within the Host Administration, should normally be approved at the highest levels of the Host Tax Administration.
Entertainment, Financial Services, Manufacturing, Mining, Oil and Gas, Other Natural Resources (forestry, farming, etc), Other Services, Telecommunications, Tourism, Trading, Transport & Logistics, and more.
Collaboration with partners:
TIWB collaborates with other technical assistance providers such as the African Tax Administration Forum (ATAF) and the World Bank Group (WBG). Partner tax administrations from the following countries have deployed or currently deploy experts to implement TIWB programmes:
- The Netherlands
- Slovak Republic
- South Africa
- United Kingdom
- United States
Coordination is also carried out with local UNDP Country Offices working in the fiscal space and regional organisations such as Cercle de Réflexion et d’Echange des Dirigeants des Administrations fiscales (CREDAF) and the Inter-American Centre of Tax Administrations (CIAT).
Types of expertise:
TIWB offers expertise in the following areas:
- Advanced Pricing Agreements
- Transfer Pricing
- Tax Crime Investigations
- Effective use of Automatically Exchanged Information
- Tax Treaty Negotiation and Administration
- Natural Resources and Environment Tax Issues
Number of in-house experts:
5 Secretariat members
40+ tax audit experts from the UNDP Roster of Experts
15+ Partner Administrations
Length of involvement:
Average duration of a TIWB programme is 12 to 24 months, involving 4 to 8 weeks of onsite assistance, coupled with remote assistance.
Fee/non-fee based support:
Non-fee based support.
Speed of response:
Usually 3-6 months.
- Government consent
- Legislation allowing for foreign experts to work on audit cases and testify in courtLinguistic competency (qualified experts having the necessary linguistic capacities)
- Human and Financial Resources
Types of negotiation support
Setting the Legal & Policy Framework Stage:
- Sector-wide analyses
- Financial structure
Contract Negotiation Stage:
- Development of a negotiation position/ strategy
- Assembly of a negotiation team
- Participation in contract negotiations
- Review of contractual provisions
- Other: Above bullets are relevant to tax treaty negotiations
Implementation & Monitoring Stage:
- Dispute resolution
Advancing Knowledge-Sharing and Management:
OECD eLearning platform available to tax administration officials and publications developed by the OECD’s Centre for Tax Policy and Administration.