Collaboration Program

Co-operative Compliance Programme is a new model for structuring the relationships between the National Revenue Administration and the largest taxpayers (with revenues in excess of EUR 50 million). The purpose is to put in place a co-operative framework that will facilitate tax compliance and allow the authorities to reduce their audits and inspections.
For those that join the Co-Operative Compliance Programme, the tax administration provides services that are custom-made to meet their specific compliance requirements.
Participation in the Programme offers numerous benefits. For example, the participants can:
• obtain present assurance as to proper application of tax law (such as by entering into interpretation agreements), apply preferential calculation of default interest for certain arrears of tax,
• enter into transfer pricing agreements with the tax administration,
• use a new simplified CIT advance payment scheme,
• avoid the MDR reporting duties (except for cross-border arrangements).

On the other hand, the Programme also provides for a number of burdens. Among other duties, the participants are required to:
• voluntarily and duly comply with their tax obligations,
• have effective and adequate processes and procedures in place to manage tax compliance (internal tax governance framework),
• give the authorities a notice, without request, of any tax issues potentially generating a tax dispute, and
• promptly give the authorities a notice, without request, of any relevant information indicating that they may obtain a tax benefit.
Participation is voluntary. To participate you need to file an application. The accession process spans a number of steps, including:
• filing an application, which is a request to execute a co-operative compliance agreement,
• meeting of the parties (including to explore whether you are eligible for the Programme),
• initial audit by the tax authorities,
• implementation of the audit recommendations (creating the internal tax governance framework),
• analysis of the internal tax governance framework by the administration,
• negotiation and execution of the agreement.

Our support

To meet the expectations of the business community, Sendero offers end-to-end support in joining and participating in the Co-Operative Compliance Programme. In particular, we will:
• review your tax compliance and procedures before initiating the application process,
• support you in preparing and filing your request for a co-operation agreement (including by offering advice on the completion of the self-assessment questionnaire),
• provide post-filing support during the period leading up to the initial audit (including assistance in pre-audit preparations),
• support you in implementing your internal tax governance framework (including tax strategy),
• support you in negotiating the co-operation agreement and in the period leading up to execution of the agreement,
• assist you in the execution of the agreement,
• provide support throughout the duration of the agreement (including in case the authorities launch what is called a monitoring audit).


• We have competences and experience that are unique country-wide – our compliance team are supporting one of the largest tax groups in the construction industry in their efforts to join the Co-Operative Compliance Programme.
• We have rich experience in formulating internal tax procedures and holding tax reviews.

Also, at your request, we will be pleased to deal with any similar matters related to this area.

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