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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 Deloitte Transfer Pricing GlobalKerwin Chung and Carlo Llanes Navarro of Deloitte provide an insight into ITR’s transfer pricing controversy guide, produced in collaboration with global transfer pricing experts from Deloitte.
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Sponsored by Deloitte Transfer Pricing GlobalEdward Morris and Jamie Hawes of Deloitte discuss how the resolution of controversy has changed with the introduction of a more efficient system to handle MAPs and APAs.
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Sponsored by Deloitte Transfer Pricing GlobalJuan Ignacio de Molina and Christine Ramsay of Deloitte consider the increased reliance of tax authorities on CbCR data and how the data reported in the CbCR during the COVID-19 pandemic could impede its use.
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