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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Multinationals face rising TP scrutiny as global rules diverge. As Daniel Moalusi argues, strong, consistent documentation is now essential to minimise audit risk and protect tax positions
While Brazil’s consumption tax overhaul led to a short-term spike in tax advisory demand, we are now in a period of ‘normalisation’ marked by decreased recruitment