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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 ChiomentiRaul-Angelo Papotti, Paolo Giacometti and Andrea Alcara of Chiomenti explain how the innovative landscape designed by the directive and domestic policies have provided new effective tools to taxpayers affected by international double taxation issues. -
Sponsored by Crowe Valente/Valente Associati GEB PartnersFederico Vincenti and Alessandro Valente of Crowe Valente/Valente Associati GEB Partners discuss advance tax agreements including changes to the roll-back of advance pricing agreements as set out in the 2021 Italian budget law.
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Sponsored by LED TaxandGuido Arie Petraroli and Francesco Cardone of LED Taxand analyse the DAC6 Directive in Italy focusing on the tax saving test, main benefit test and hallmark C1, in relation to inter-company debt financing.
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