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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 HLB ThailandPaul Ashburn and Amit Bhalla of HLB Thailand overview Thailand’s gradual overhaul of its transfer pricing rules, as the concept of secondary adjustments takes shape in the jurisdiction. -
Sponsored by KPMG ChinaLewis Lu and John Timpany of KPMG China discuss the bright-line test to be introduced for treating certain onshore equity disposal gains as capital in nature and non-taxable.
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Sponsored by Gatti Pavesi Bianchi LudoviciPaolo Ludovici and Andrea Iannaccone of Gatti Pavesi Bianchi Ludovici examine the recent judgment, which declares that even payments between resident entities must be scrutinised.
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