This report was published during the 6th OECD Forum on Tax and Crime, held in Rome, Italy, on 5-7 December 2023, which gathered the heads of tax crime investigation agencies from around the world, together with other key stakeholders in the fight against tax crime, senior representatives of other financial crime agencies, and regional and international organisations.
Based on the experiences of a number of jurisdictions, it seeks to raise awareness among investigators and policymakers of different schemes that have been used to circumvent the payment of dividend taxes, including through co-ordinated cross-border activities.
Some of these schemes, which can result in substantial revenue losses, have been categorised as criminal behaviour by domestic courts, while others may fall within the realm of tax avoidance or aggressive tax planning. As well as describing some of the most commonly seen schemes, the report suggests a series of countermeasures that jurisdictions may wish to consider to address abusive dividend stripping.
These include raising awareness among key stakeholders, both public and private sector, improving domestic co-ordination and expanding international co-operation mechanisms. In particular, it suggests that jurisdictions may wish to consider establishing timely and efficient sharing of information between supervisory authorities, tax authorities and law enforcement to detect dividend stripping schemes, as well as to set up cross-agency joint investigation teams where appropriate.