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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 DeloitteVrajesh Dutia of Deloitte India and Jennifer Breeze of Deloitte UK assess the complex arm’s-length decisions that global businesses had to make during the COVID-19 pandemic, and the various responses from international tax authorities. -
Sponsored by DeloitteAriel Krinshpun and James Mahon, III of Deloitte US and George Galumov of Deloitte Switzerland analyse two areas of intercompany financing arrangements as transactions come under increasing scrutiny from tax authorities.
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Sponsored by DeloitteAaron Wang of Deloitte China and Iva Georgijew of Deloitte Poland set out the key questions when limited risk and low-risk distributors incur losses, and consider the challenges presented in several common scenarios.
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