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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The firms made senior hires in Los Angeles and Cleveland respectively; in other news, South Korea reported an 11% rise in tax income, fuelled by a corporation tax boom
While the manual should be consulted for any questions around MAPs, the OECD’s Sriram Govind also emphasised that the guidance is ‘not a political commitment’
The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, rejects protections for indirect transfers and tightens conditions for Mauritius‑based investors claiming DTAA relief
As tax teams face pressure from complex rules and manual processes, adopting clear ownership, clean data and adaptable technology is essential, writes Russell Gammon, chief innovation officer at Tax Systems