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Fairness in tax and the OECD Tax Control Framework: Hilde Wampers, Managing Director at, explains new trends in corporate tax planning


Hilde Wampers, Managing Director of, is an experienced tax professional who closely follows the theme of corporate tax planning. Over the past decades, she has seen this field of expertise change rapidly and drastically. How does she assess striking novelties and points of interest based on her own work experience? And how do you best deal with supervision as a company?

From 'responsibility of tax' to 'morality of tax'
Hilde Wampers sees a major challenge for companies in finding a balance between maximum cost reduction (combined with tax optimisation) and investing in society: “New phenomena such as 'responsibility of tax' and 'morality of tax' are fueling discussions between taxpayers and their stakeholders on the alert. On the one hand you have the proposition 'tax is the cost of doing business', whereby you try to reduce the operating costs as much as possible – within the legal guidelines of course. On the other hand, the statement 'tax is the price you pay for a civilized society' applies. Personally, I think that a tax department within a company should be given all the resources and space to continue exploring tax-efficient optimization techniques at the request of the business.

Consultation with tax authorities: 'it takes two to tango'
How does Hilde Wampers feel about consultation with the tax administration and the ruling service? “Of course I welcome constructive consultation between the administration and the taxpayer. After all, it is important to be able to discuss tax files with the tax authorities in all transparency. But that transparency must be based on expertise and trust. It is difficult to work in an atmosphere of suspicion and suspicion. Corporate compliance aims to ensure that a relationship of trust is created between civil servants and taxpayers (a so-called “authentic trust”, with an understanding of each other's roles). Making good agreements about openness on both sides of the table is a good thing. But this does require a mind shift.”

Rulings as 'sweetheart deals'?
Hilde Wampers regrets that tax rulings are still perceived too much as 'sweetheart deals' between taxpayers and tax authorities. “During my career I always had good contacts with the administration, even during inspections. I invested heavily in a respectful relationship with tax auditors. As a company you are looking for security to limit risks, especially for large transactions. Therefore, I do not agree with the perception that rulings are 'sweetheart deals'. On the contrary: they are clarifications of tax legislation where possible alternative routes are available, where you as a taxpayer argue what the facts are and how you apply the law.”

How to deal with the OECD Tax Control Framework?
Due to the increased importance of morality and compliance, supplemented with additional compliance burden due to country-by-country reporting, the impact of the additional workload for internal tax professionals is often underestimated. Hilde Wampers explains: “With the OECD Tax Control Framework, it is all hands on deck for many tax departments to ensure that each type of tax flow is the right one for all group entities. This extra documentation and reporting obligation is very extensive, because all fiscal areas – corporate tax, VAT, customs duties, payroll tax, exemptions, local tax – come into focus. At the same time, there is a growing need for governance of the tax function, because incorrectly applied tax planning can cause unwanted reputational damage and associated negative media attention.

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