Patrick Connolly is an experienced senior in-house tax adviser who has spent the past 10 years in in-house regional tax roles covering Europe, the Middle East, Africa and the Asia/Pacific regions as well as head office tax responsibilities. He shares his views on getting the most value from the client/adviser relationship. Paul Dunne, national managing tax partner for KPMG New Zealand and the tax lead on a number of multinational clients, provides his response and comments.
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Valid pillar two objectives are still intact after the side-by-side agreement, but whether the framework is now settled is ‘a $64,000 question’, Morrison Foerster’s tax chair told ITR
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