Cooperative Compliance Program for Individuals and Trusts: A Proposal for a Compliance Passport

Philip Marcovici, Noam Noked


Ensuring tax compliance among business and wealth owners is an important policy goal for many tax authorities. This article develops a proposal for a voluntary program for  individuals, family trusts, and private investment vehicles, which draws upon existing cooperative compliance programs for large corporations, such as the Organisation for Economic Co-operation and Development (OECD)’s International Compliance Assurance Programme (ICAP). Under the proposed program, the authorities of the relevant jurisdictions would determine, on a joint basis, whether the participant is in full compliance with their tax obligations and whether there are any money laundering concerns. The implementation of this proposal could enhance a culture of cooperative compliance and free up enforcement resources. For participants, it could improve privacy, increase certainty, and reduce compliance costs and distortions. As this proposal has the potential to ensure compliance while reducing costs and risks for both tax authorities and taxpayers, it deserves serious consideration.

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