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The scope of qualifying pillar two tax credits could reportedly be broadened; in other news, hundreds of IRS appeals staff are to resign
Levine, who served under the Joe Biden administration, led the US’s negotiations on the OECD’s two-pillar solution
Scott Bessent reportedly felt undermined by Musk naming Gary Shapley as acting IRS commissioner; in other news, Baker Tilly will combine with a top 15 US firm
The promise of nine years’ tax certainty and a ‘rational and pragmatic’ government process makes APAs a no-brainer, Indian tax advisers tell ITR
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Sponsored by Tax PartnerMonika Bieri and Caterina Colling Russo of Tax Partner discuss a Swiss court ruling concerning the use of multi-year margin averaging in transfer pricing adjustments and suggest several steps that could help ensure compliance
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Sponsored by Deloitte LuxembourgEdouard Authamayou and Christelle Larcher of Deloitte Luxembourg explain how several recent rulings have clarified the Administrative Court’s stance on the application of ex officio taxation in the grand duchy
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Sponsored by DLA Piper NetherlandsJian-Cheng Ku, Xander Stubenrouch, and Isa Weijman of DLA Piper Netherlands explain a recent ruling by the Amsterdam Court of Appeal regarding dividend stripping, and its broader meaning in an evolving tax landscape
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