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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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    Andrea Silvestri, partner, and Paolo Ronca, associate, at BonelliErede explain the key amendments to Italy’s controlled foreign corporation (CFC) rules that have been introduced to align the country’s laws to the EU’s Anti-Tax Avoidance Directive (ATAD).
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    Italy’s Supreme Court has issued a controversial decision on the requirements necessary to benefit from withholding tax (WHT) exemptions on profits distributed to companies resident in other EU member states. Chiomenti’s Paolo Giacometti and Raul-Angelo Papotti discuss what this means for the Parent-Subsidiary Directive.
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