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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 MDDPMarta Klepacz of MDDP explains that the application of transfer pricing changes to third-party transactions has placed a burden on taxpayers, not least because of the difficulty in identifying the suppliers in indirect transactions.
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Sponsored by QCG Transfer Pricing PracticeMiguel Ángel García Piña of QCG Transfer Pricing Practice explains the complications for Mexican taxpayers now that business reason has been firmly embedded as a concept under recent reforms, but with uncertainties remaining.
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Sponsored by KPMG Hong KongLewis Lu and John Timpany of KPMG China discuss the implications of a proposed refined foreign source income regime in Hong Kong for constituent entities of multinational enterprises.
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