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 MachadoBrazil has affirmed that sales to the Amazonian free trade zone of Manaus must be equal to export transactions. Machado Associados' Ricardo Debatin da Silveira and Rogério Gaspari Coelho discuss the implications for exporters over the last five years.
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Sponsored by Mattos FilhoBrazil's tax authorities may now establish liability of third parties before court judgement. Mattos Filho's Ana Paula S. Lui Barreto and Leonardo Fernandes Rebello discuss the impact to third parties and their defence.
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Sponsored by MachadoBrazil’s Superior Court of Justice (STJ), which has the power to deliver final decisions regarding legality (constitutional matters are addressed by the Brazilian Supreme Court – STF), has reaffirmed that sales to the free trade zone of Manaus (FTZM) – which is in the state of Amazonas – must be equal to export transactions. Companies that have sold inputs or merchandise to the FTZM can therefore recover tax credits to foster exports, under the Special Regime for Reintegrating Tax Values for Exporting Companies (REINTEGRA).
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