Schedule UTP has been been the subject of intense debate within corporate tax circles since the IRS announced the programme in January 2010. However, this programme is just the latest in a long line of IRS initiatives aimed at enhancing taxpayer transparency. Eli Dicker, chief tax counsel of the Tax Executives’ Institute, questions whether or not Schedule UTP will fundamentally alter the landscape.
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Despite the relief, Brazil’s government has also presented a bill which seeks to re-impose a tax burden on companies’ payroll, one local tax specialist told ITR
While successful pillar two implementation will require collaboration across all units, a combination of internal and external tax advice is at the centre of the effort