The European Trust and Cooperation Approach as Experienced: Practical Insights from the First EU Pilot Phase

ETACA is the European Union’s cooperative compliance initiative for transfer pricing, based on multilateral dialogue and joint risk assessment rather than binding outcomes. Drawing on the direct participation of the authors in the first pilot (2021-2024), this article provides practical insights into how the programme operates in practice, with a particular focus on the challenges encountered, including documentation, coordination and timelines, and the key lessons learned from the various conceptual approaches adopted by the tax authorities involved. These observations offer a grounded perspective on ETACA’s ability to enhance practical tax certainty and suggestions from the taxpayer’s and the tax adviser’s perspectives.