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 KPMG RussiaDmitry Garaev and Anastasia Avdonina of KPMG discuss the Supreme Court’s decision A47-9881/2017 of August 26 2019, which is of specific interest for companies receiving both operating profit and dividend income. -
Sponsored by Chevez Ruiz ZamarripaOscar Campero and Yoshio Uehara of Chévez Ruíz Zamarripa y Cía analyse the requirements of economic substance and arm's length.
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Sponsored by PwC BrazilOn July 1 2019, the Federal Brazilian Tax Authorities (RFB) published Solução de Consulta – Cosit 210/2019 (dated June 24 2019), providing that withholding tax should be levied at a rate of 15% on interest that is accrued but not yet due, where the outstanding debt is used to reduce accounting losses of a Brazilian company via a ‘debit to shareholders account’ transaction.
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