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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Experts reportedly discussed extending the safe harbour to 2027 to give countries more time to legislate; in other news, Baker McKenzie and Greenberg Traurig made senior tax hires
Hany Elnaggar examines how Gulf Cooperation Council countries are internalising transfer pricing norms within evolving fiscal systems shaped by both Islamic and international influences
Where a TP study of comparables produces an arm’s-length range, and the taxpayer’s filed position is outside that range, HMRC will adjust to the median by default