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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 USMarco Fiaccadori, Arindam Mitra, and Robert Plunkett explain how to reconcile the licensor-licensee profit split approach with the income approach. -
Sponsored by Deloitte USAs energy firms discover and exploit new reserves which require significant amounts of financing, tax authorities have increased their focus on the intra-group financing transactions of such companies. Randy Price, Nadim Rahman and Bill Yohana of Deloitte investigate why the materiality of these transactions may have also increased taxation authority interest in the intra-group financing transactions of energy firms.
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Sponsored by Nagashima OhnoJapan will reduce its corporate tax rate by five percentage points to 35% from next April, in an effort to boost the country’s ailing economy.
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