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New reforms represent the most seismic shift in Canadian TP legislation since its enactment and a clear inflection point for MNEs, ITR has heard
The new office on the fourth floor of 4 More London will span 14,230 square feet, with the potential to expand to the first and second floors
MNEs now face a shift from modelling to execution as the side‑by‑side deal forces tax teams to upgrade systems, harmonise data, and prevent costly pillar two mismatches
As recent surveys suggest a disconnect between AI adoption and employee engagement, the big four risk digging themselves into a strategic hole
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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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