On July 23 2004 the Italian central tax agency issued the explanatory notes (the Explanatory Notes) envisaged by article 8(2) of Law Decree 269, of September 30 2003 (Decree 269) necessary to allow certain enterprises that carry on an international activity (each an International Enterprise) to apply for the ad-hoc ruling procedure (the International Ruling Procedure) established by article 8 of same Decree 269
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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