Practitioners have said the decision to move responsibility for the US advance pricing agreement programme (APA) and mutual agreement procedure (MAP) from the Office of Chief Counsel to the IRS commissioner has as much to do with the faith in the ability of Mike Danilack, deputy commissioner (international) of the Large and Mid-Size Business Division (LB&I), as it has to do with efficiency.
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Hany Elnaggar examines how the OECD’s global minimum tax is reshaping PE concepts across the GCC, shifting the focus from formal presence to substantive economic activity
Following Richard Houston’s switch to the newly formed Deloitte EMEA, Graves has the opportunity to bring Deloitte’s tax practice up to speed with its rivals
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