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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
Ian Halligan previously led Baker Tilly’s international tax services in the US
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
Salim Rahim, a TP specialist, had been a partner at Baker McKenzie since 2010
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Sponsored by CuatrecasasAna Helena Farinha and Tiago Martins de Oliveira of Cuatrecasas say that the intragroup financing of Portuguese companies could be affected by a rule that is out of kilter with several other EU jurisdictions
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Sponsored by KPMG USMark Martin and Thomas Bettge of KPMG in the US discuss the tax certainty provisions of the Multilateral Convention for amount A and evaluate their utility for businesses
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Sponsored by Gatti Pavesi Bianchi LudoviciPaolo Ludovici and Andrea Iannaccone of Gatti Pavesi Bianchi Ludovici argue that a decision by the Italian court violates the European freedoms in treating a non-resident taxpayer differently from resident entities without justification
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