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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Ireland’s Department of Finance reported increased income tax, VAT and corporation tax receipts from 2024; in other news, it’s understood that HSBC has agreed to pay the French treasury to settle a tax investigation
The EU has seemingly capitulated to the US’s ‘side-by-side’ demands. This may be a win for the US, but the uncertainty has only just begun for pillar two