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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 South America
    South America is in the throes of implementing the OECD BEPS project with new regulations emerging from every corner of the region, write Deloitte’s Latin America Countries Organisation practitioners. The developments clearly signal a tougher stance by authorities on transfer pricing and indicate that advance pricing agreements may be a key tool of the future.
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    The subject of transfer pricing (TP) has gained a great deal of momentum globally over the past couple of years. Most of the OECD and G20 countries have implemented TP legislation even before the BEPS initiative and have issued further regulations considering the recommendations of the BEPS Action Plan reports.
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    Gian Luca Nieddu and Barbara Scampuddu of Hager & Partners analyse the new tax provisions concerning repatriated employees as well as brain gain tax advantages.