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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 KPMG USMark Martin and Cameron Taheri of KPMG take a closer look at the IRS's APA statistics for 2017. -
Sponsored by NeraIn the first of a series on transfer pricing technical challenges and solutions to changing economic and regulatory environments for global multinationals, this article focuses on the remuneration of top management functions in the inter-company context.
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Sponsored by PwC ChileOver the years, the Chilean IRS has issued a number of rulings on how to apply Article 12 (royalties) of double tax agreements (DTAs). These have been particularly in regard to the taxation over payments made from Chile to overseas countries for distribution rights, and their characterisation as intangible property.
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