The world of international taxation becomes more transparent with every passing year. This reflects the desire of global tax authorities to achieve compliance efficiency, prevent the inappropriate avoidance of taxpaying obligations and promote equity among taxpayers.
There have been many elements of transparency in recent years, including transfer pricing documentation in more than 70 countries, FIN 48 (ASC 740) for financial reporting purposes, UTP Schedule for U.S. tax purposes, and exchange of information agreements between Organisation for Economic Co-operation and Development (OECD) member and non-member countries.
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