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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 PwC ChileAs a rule, remuneration for services – digital or otherwise – rendered by a non-resident non-domiciled in Chile to Chilean taxpayers are subject to a withholding tax, with rates of up to 35% over the full paid amount depending on the type of service. -
Sponsored by Webber WentzelChanges made last year to South Africa's dividend stripping rules have effectively eliminated the ability of group companies to make use of the rollover relief provisions that historically have allowed qualifying liquidations or deregistration of group companies (both local and foreign) to be done on a tax-neutral basis.
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Sponsored by Garrigues PortugalA recent Portuguese Arbitration Court decision (Case 639/2017-T), dealing with the application of the exemption method to foreign-based liquidation proceeds for non-habitual tax residents serves as a good illustration of how this domestic exemption works.
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