Firm
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 Garrigues SpainMaría Cenzual and Marta Gràcia of Garrigues report on the Supreme Court overturning the Spanish tax authorities’ stance that borrowing costs in certain circumstances should be treated as gratuities for corporate income tax purposes. -
Sponsored by Deloitte NorwayDaniel Herde and Lene Bergersen of Deloitte Norway explain a statement from the Ministry of Finance on the relationship between Article 8 (shipping income) and Article 12 (royalties) in double tax treaties.
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Sponsored by DLA Piper AustraliaEddie Ahn of DLA Piper Australia provides an update on the Minerva Financial Group v Federal Commissioner of Taxation case, which considered the application of Australia’s general anti-avoidance rules to a business restructure.
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