Overview
Larry Hill submitted commentary to the OECD Centre for Tax Policy and Administration in response to its Public Consultation on Global Mobility of Individuals, offering policy recommendations drawn from decades of experience advising multinational corporations and individuals on complex cross‑border tax controversies.
Larry points to Spain’s Impatriate (Beckham) Law as a prominent example of how inconsistent or aggressive administration of incentive regimes can undermine taxpayer trust. He highlights concerns about late‑stage audits, procedural barriers to appeal, and coercive enforcement tactics, noting that such practices can create significant financial and personal hardship for individuals, and conflict with OECD principles on fairness and tax morale.
To address these risks, Larry urges the OECD to develop best‑practice guidance, expand peer review mechanisms, and draw on the Platform for Collaboration on Taxes established tax‑incentive principles. He recommends greater focus on how residency‑based incentive programs are designed, administered, and implemented in practice, concluding with a call for continued dialogue among governments, taxpayers, and practitioners to promote transparency, certainty, and effective dispute resolution.
