Kuwait EY 4
France Allen & Overy France 5 Germany PwC Germany 6
The Netherlands KPMG Holland 7 Spain Giambrone New Zealand Buddle Findlay
Romania Dentons India Lakshmikumaran & Sridharan
Israel Pearl Cohen
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KUWAIT Alok Chugh Partner EY +965 22955104 www.ey.com alok.chugh@kw.ey.com Baitak Tower, Ahmed Al Jaber Street, P.O. Box 74, Safat 13001, Kuwait
Alok is a partner with EY’s Middle East practice and is based in Kuwait. He has lived and worked in Kuwait for over 24 years and has detailed knowledge of business and taxes in Kuwait. He has considerable experience in advising entry level strategies for foreign multinationals wishing to do business in Kuwait. Alok has been involved in a number of consulting assignments (including cross-border planning, application of double tax treaties and the efficient handling of tax and commercial affairs) for project due diligence, business paper preparation or review, and structuring operational activities). Alok is a member of the Institute of the Chartered Accountants of India and is an active member and frequent lecturer at the American Business Council, French Business Council, British Business Forum and Canadian Business Council in Kuwait. He is also on the Board of the American Business Council in Kuwait. Alok has been consulted by various government organizations in Kuwait on the practical implementation of various regulations in Kuwait, including the Ministry of Finance and National Offset Company.
Alok also works closely with the Kuwait Direct Investment Promotion Authority (KDIPA) and a number of other government institutions. EY in Kuwait has been operating since 1952 and is the largest accounting and consulting firm in the country. Our 340 professionals are available to serve clients anywhere in Kuwait working in both Arabic and English. EY professionals in Kuwait can provide expert advice on every business issue. We are fully integrated with Ernst & Young Middle East in terms of methodology, training and quality control. The Kuwait office is supported by resources of Ernst & Young Global, which has over 152,000 professionals working out of 700 offices in over 140 countries. Ernst & Young, Kuwait enjoys the premier position as tax advisers in Kuwait. With 2 specialist tax partners, 4 directors and a team of 40 tax specialist staff we service approximately 70% of registered taxpayers in Kuwait. We have an extensive experience of assisting companies in managing their tax compliance in Kuwait in the most efficient manner, advising on tax treaty matters and providing for entry-level strategies to foreign companies intending to carry on business in Kuwait.
Key achievements/experience of the firm •
Over 70% share of the of tax services in Kuwait
•
Over 50 years of experience in Kuwait
• A large team of Tax professionals with one Tax partner, five Tax directors and a team of 40 other experienced staff, including several bilingual staff, who are dedicated to handling matters with the Kuwait tax authorities • Assisted 4 out of 9 investors who have been granted license under Law 116 of 2013 (foreign investment law)
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FRANCE Jean-Yves Charriau Partner Allen & Overy LLP +33 1 40 06 54 00 www.allenovery.com jean-yves.charriau@allenovery.com 52 avenue Hoche, 75008 Paris, France
Bio Jean-Yves Charriau is a partner in the tax department of Allen & Overy LLP Paris. He specialises in the structuring and financing of foreign and French real estate investments and has developed a particular expertise with respect to French REITs, OPCIs, Anglo-Saxon and Islamic funds. Jean-Yves advises many listed real estate companies and foreign funds on their real estate investment transactions in France and abroad. He acts as an adviser of the French property federation (FSIF) on tax matters.
Since 2003, Jean-Yves has also been involved in the first real estate transactions carried out by Islamic investors in France and he has been one of the key contacts of the Ministry of Finance in relation to the adoption of new regulations adapting French taxation to the requirements of Islamic finance. He is a member of the Islamic Finance Commission set up by Paris Europlace.
Our network combines broad international cover with deep local roots, and we are present in those locations which are the source or destination of the major international capital flows and in the financial centres that handle those flows.
The Firm
Our clients require a seamless, multijurisdictional tax advisory service, whether on a stand-alone basis or as an integral part of the full legal service which we offer.
Allen & Overy is one of the largest international legal practices with approximately 5,200 staff and some 525 partners within 43 offices in 30 countries across Europe, Asia Pacific, the US, South America and the Middle East.
That’s why, with over 100 tax specialists across our international network, we are able to offer both domestic and cross-border advice wherever our clients need it, whether they are financial institutions, corporate entities or funds. The depth and breadth of our knowledge ensures that we are able to support our clients’ business needs successfully and provide highquality, innovative tax solutions in the increasingly complex area of tax legislation and practice.
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GERMANY Lorenz Bernhardt Partner / Leader Transfer Pricing PricewaterhouseCoopers +49 30 2636 5204 www.pwc.de lorenz.bernhardt@de.pwc.com Kapelle-Ufer 4, 10117 Berlin
Bio Lorenz has over 20 years experience in tax consulting, in particular in planning, implementation and defense of transfer pricing systems as well as in international tax structuring. He advises large international clients (both German and foreign headquartered) and has led many projects with a broad variety. He is also acting as central European transfer pricing advisor for a number of multinational corporations. Additionally, Lorenz lectures on transfer pricing and international tax at professional seminars and at renowned universities. He is regularly named to be one of the top tier transfer pricing advisors in Germany.
Recent projects of Lorenz Bernhardt included: •
Advice on and implementation of large restructuring projects, including treatment under the German transfer of function rules;
•
Advice on intra-group financing structuring, including design of overall transfer pricing systems for group financing activities as well as determination of interest rates, guarantee fees etc. through loan benchmarking and other pricing techniques; and
Education Lorenz obtained a law degree from the University of Munich and an LLM from New York University School of Law. Before joining the tax practice of an international accounting firm in Germany, he had been working as a foreign associate with Fried, Frank in New York. Lorenz is a German certified tax advisor and has been admitted as attorney-at-law both to the German Bar as well as to the New York Bar.
The Firm
Our clients face diverse challenges, strive to put new ideas into practice and seek expert advice. They turn to us for comprehensive support • Tax audit defense work with and practical solutions that deliver a focus on very large cases maximum value. Whether for a and high end transfer pricing global player, a family business or matters a public institution, we leverage all of our assets: experience, industry Lorenz is also heading the German knowledge, high standards of transfer pricing practice of quality, commitment to innovation PricewaterhouseCoopers, and is and the resources of our expert member of pwc’s global transfer network in 157 countries. Building a pricing leadership team. Under trusting and cooperative relationship Lorenz’ leadership, pwc Germany’s with our clients is particularly transfer pricing practice has grown important to us – the better we know substantially and now encompasses and understand our clients’ needs, more than 160 professionals located the more effectively we can support in all major German cities. them. PwC. 9,300 dedicated people at 28 locations. €1.55 billion in turnover. The leading auditing and consulting firm in Germany.
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THE NETHERLANDS Jaap Bellingwout Partner +31 (0)88 909 10 58 bellingwout.jaap@kpmg.com
Experience With over 20 years of experience in international corporate taxation as a tax professional, Jaap is servicing large clients based around the world, with a focus on the US and on the MENA region. In his client portfolio, Jaap has established numerous holding company structures, financing structures and tax efficient acquisition and investment structures for (mostly: listed ) companies in various sectors of industry, including foreign banks, as well as investment funds and sovereign wealth funds. Jaap has also been a trusted advisor to various governments on the implementation and modernization of their tax regimes, including in the Middle East. Jaap has advised governments on tax strategic matters such as corporate tax reforms,
the introduction of withholding taxes and VAT, the protection of domestic (corporate) tax bases, and alignment with international
standards of the OECD and the EU. Jaap has also negotiated several tax treaties on behalf of a jurisdiction, and he initiated and supervised the introduction of a new legal entity type in this jurisdiction. Recently, Jaap successfully represented a government in the OECD’s Global Forum Peer Review Project, resulting in this jurisdiction passing Phase 1 of this OECD project. Within the Dutch Organization of Tax Advisors Jaap is member of a core team interacting with the Dutch stakeholders (a.o. the Dutch MoF, Parliament, and Dutch business organization VNO-NCW) in light of how the Netherlands should respond to the international debate and OECD/EU action plans on base erosion & profit shifting/aggressive tax planning.
Specialization •
Corporate income tax
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Dividend withholding tax
•
International and European tax law
• Divisions •
Tax planning and structuring
•
Mergers and acquisitions
Education and memberships Master’s in Tax Law, & Master’s in Business Law, Leiden University PhD (Legal and Tax Aspects of Company Migration in the EU), Radboud University Nijmegen Lawyer, Admitted to the Bar in Amsterdam Member and vice chairman of the legislative committee of the Association of Dutch Tax Advisors (since 1996) Elected as ‘Best tax lawyer in the Netherlands’ by Advocatie.nl (2005) & ‘Winner ‘of the Corporate Livewire Global Awards 2015 for the Netherlands ,category‘Tax’; Appointed by the Crown as a member of the Committee on Company Law, advising the Dutch Minister of Justice Jaap is also Professor and Head of Department at VU University Amsterdam
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SPAIN Paola Vitali Partner Giambrone (Spain) LLP +34 932 201 627 Barcelona@giambronelaw.com Paseo de Gracia 12, 1 Planta08007 Barcelona, Spain
The Firm Giambrone (Spain) LLP is part of Giambrone, a mid-tier international law firm established in 2004; founded with just two offices we now have developed offices in London, Milan, Rome, Palermo, Munich, Barcelona, Mallorca, Tunisia, Sardinia, we also have capacity in the Middle East. Our reach across Europe and the Mediterranean makes us well positioned to assist our clients with a broad range of crossborder issues. We have the capacity, under one roof, to successfully navigate through many different jurisdictions saving our clients’ time and money. Giambrone’s experienced lawyers have the capacity to offer a range of competence and services rarely seen, other than in far larger firms. Giambrone is committed to excellence and we have developed teams of multi-specialist, multi-lingual and multijurisdictional lawyers in recognition of the frequent over-lap of expertise required when addressing our clients’ complex cross-border issues. The range of services available to assist our private clients extends from complicated cross-border divorce including the sensitive issues surrounding access to children, we also assist with disputed cross-border inheritance matters, as well as real estate, immigration and personal injury. Our corporate and commercial lawyers regularly assist clients with cross-border mergers & acquisition, business re-location, banking & finance and we also have a robust litigation team. New Insolvency Rules for Cross-border Matters aimed at keeping the Creditors and the troubled Business on Course came into force in June 2017 In June 2017 new rules relating to cross-border insolvency debt recovery came into force. The intention is of the new rules is twofold, to enable an easier path to restructure for the failing business and to assist the creditors of the company to recover their money from the insolvent company. The new rules focus on preventing and resolving conflicts of jurisdiction, which can arise, and crucially recognises insolvency-related judgments across the European Union. Frans Timmermans, the European
Commission First Vice-President commented, «In a real internal market, businesses that need to restructure should not be hampered by conflicts over which national rules apply, nor should national borders be an obstacle for creditors to recover their claims. These new rules will support companies and investment through increased legal certainty. We will need to go further and adopt common EU rules to make sure companies restructure early, as already proposed by the Commission.» Commissioner Věra Jourová, EU Commissioner for Justice, Consumers and Gender Equality, supported the view that there should be the maximum opportunity to facilitate the recovery of a business so that it can go forward and become a viable entity once again; he also felt that the new rules would discourage bankruptcy tourism which has been seen in the past. The new rules on restructuring and second chances will remove barriers for investments and support honest entrepreneurs and create even ground across Europe. The main features of the new regime aim to provide a different environment for the restructured business to operate within, removing many of the existing barriers to a successful turnaround for businesses that have experienced setbacks. The platforms on which the new rules are based are as follows: • • •
The new rules offer a wider range of restructuring proceedings, employing efficient and up-to- date practices, not covered previously by the old rules, therefore they could not be used in cross-border matters. Bankruptcy tourism will be curtailed as the court will be able to examine the circumstances of a case if the debtor relocates shortly before filing for insolvency. The court can then make a decision as to whether the relocation was genuine or executed to take advantage of more lenient bankruptcy rules in a different jurisdiction. The limitation of “secondary rules” whereby proceedings are opened in a court within the EU
but in a country other than the country that the business has its registered office. Avoiding this will make it easier to restructure companies in a cross- border context and will at the same time provide for safeguards guaranteeing the interests of local creditors. • The new rules introduce framework for group insolvency proceedings, which will significantly increase the potential to rescue the entire group, rather than breaking up the organisation into separate parts. • By the summer of 2019 it is anticipated that there will be an EU-wide interconnection of electronic national insolvency registers. This will signal a significant step forward by making it easier to obtain information on insolvency proceedings in other EU countries. There has been an appetite for change in the way insolvency is managed across Europe to make it easier for a failing business to be turned around and continue trading whilst at the same time protecting the interests of the creditors since 2012 when a proposal was put forward by the European Commission. A framework supporting entrepreneurs and ensuring sound growth was created with a strong emphasis on early intervention and restructuring to facilitate a second chance whilst limiting the risk to creditors. It is hoped that businesses will come forward earlier when they start to experience problems to allow for a rescue plan to be put in place before there is a significant impact on both their creditors and the business. If caught early there is nearly always the opportunity to provide a solution which keeps the business on track and trading. Paola Vitali and her team have extensive experience in complex cross-border insolvency matters and have broad expertise in assisting businesses in a variety of ways to remain trading through restructuring despite having had commercial setbacks.
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NEW ZEALAND Neil Russ Partner Buddle Findlay +64 9 358 7002 http://www.buddlefindlay.com/ neil.russ@buddlefindlay.com PwC Tower, 188 Quay Street, Auckland 1010, New Zealand, PO Box 1433, Auckland 1140, New Zealand
Bio EXPERTISE Corporate and international taxation (income tax and GST), including extensive experience with specialist banking products, new business structures, structured and acquisition financing. Multi-jurisdictional asset and merger and acquisition transactions. EXPERIENCE • Leader of Buddle Findlay’s national tax practice since 1995 •
Frequently involved in large and innovative commercial transactions, including new business structures, acquisition structures, amalgamations and mergers
•
Dealing with the tax implications of industry and legislative reform, including clients in the banking, charity, co-operative, energy, film, local government and trustee company sectors
•
Advising banks, New Zealand corporates, foreign corporates, private equity funds and foreign counsel in relation to cross- border structured financings (inbound and outbound), acquisitions and dispositions
• Experienced in dealing with contentious and non-contentious dealings with revenue authorities in New Zealand and other jurisdictions • Author of the New Zealand chapter of Tolley’s International Investment Guide •
Listed as a leading practitioner in Chambers Global, and listed in the top 250 tax practitioners worldwide in the Tax Directors Handbook 2011
AFFILIATIONS/MEMBERSHIPS • New Zealand Law Society Taxation Committee (Convenor) • Inter-Pacific Bar Association (NZ Jurisdictional Council Member) • LawAsia • International Fiscal Association • Taxation Institute of Australia
The Firm Buddle Findlay is one of New Zealand’s pre-eminent commercial law firms with offices in Auckland, Wellington and Christchurch. The firm has 42 partners and over 260
dedicated staff with our origins dating back over 119 years, to the earliest days of legal practice in New Zealand. Buddle Findlay is progressive, dynamic and at the forefront of the legal profession. We have an open and approachable client-focused culture, with a determination to continually provide the highest quality of service. Buddle Findlay’s highly experienced partnership brings an energy and enthusiasm to New Zealand’s legal market. Its practical approach has made it a valued strategic adviser to its clients thanks to its ability to provide balanced advice within a broader commercial context. Buddle Findlay provides the full range of services to the corporate and public sector, including corporate and commercial advice, banking and finance, public and administrative law, competition law and industry regulation, property and construction, employment, environment and resource management, litigation and dispute resolution, information and communication technology, procurement, insolvency and restructuring, climate change, health law, infrastructure, intellectual property and tax. Buddle Findlay’s clients include national and multinational corporations, private equity and venture capital funds, banks and financial institutions, stateowned enterprises, government departments, and local and other statutory authorities. Buddle Findlay also has strong links with law firms in Australia, United Kingdom, United States of America and Asia. Further information about the firm and our specific areas of expertise can be found on our website.
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ROMANIA Delia Dragomir Managing Counsel, Head of Tax practice Dentons + 40 21 312 4950 www.dentons.com delia.dragomir@dentons.com 28-General Constantin Budisteanu Street, Sector 1, 010775 Bucharest, Romania
Bio Delia Dragomir focuses primarily on fiscal and administrative litigation as well as tax, corporate and M&A and capital markets. In her over 12 years of experience, Delia has assisted large international clients from various industries, including automotive and retail, on litigation matters and was involved in several major transactions for media, FMCG or insurance companies. She graduated West University Law School in Timisoara, Romania and holds a Master in Political Sciences from Central European University,
Budapest, Hungary as well as a Diploma from Johns Hopkins University, Bologna Center, Italy. Delia is a member of Arad Bar (Romania) and speaks Romanian, English, French and Italian.
The Firm Dentons is a global firm driven to provide clients with the competitive edge in an increasingly complex and interconnected marketplace. It was formed by the March 2013 combination of international law firm Salans LLP, Canadian law firm Fraser Milner Casgrain LLP (FMC) and international law firm SNR Denton. Clients benefit from approximately 2,600 lawyers and professionals in more than 75 locations in 50-plus countries across Africa, Asia Pacific, Canada, Central Asia, Europe, the Middle East, Russia and CIS, the UK and the US who are committed to challenging the status quo to offer creative, actionable business and legal solutions.
Dentons Bucharest (Salans until the end of March 2013) is one of the oldest international law firms in Romania, with a presence of over 17 years on the local market. The firm has one of the leading law practices in the country, owing its success to its attorneys’ commitment to knowledge of the law, culture and commercial life of the region. Large international corporations and local entrepreneurs as well as public institutions and institutional investors have used our specialized services within a wide range of transactional and nontransactional matters. Our lawyers have often set the pace for the industry as they have been involved in cornerstone projects shaping the country’s commercial landscape. The firm is constantly selected by independent prestigious directories such as Legal 500, Chambers & Partners and PLC Which Lawyer? as leading and recommended practices and practitioners in Romania.
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INDIA GAYATRI SRIDHARAN Principal Associate Lakshmikumaran & Sridharan, Attorneys 9886719861 www.lakshmisri.com gayatri.sridharan@lakshmisri.com
Supreme Court interprets “Amount Payable” for disallowance for not Withholding Tax
Summary The Honorable Supreme Court of India in a recent Judgment in the case of Palam Gas Agencies ltd. set at rest a controversy which has been raging in the Income Tax circles from 2012.The moot question before the Hon’ble Supreme Court was whether the expression “payable” used in Section 40(a)(ia) means payable at the end of the year or payable at any time during the year though paid during the year itself.
Background Section 40(a) (ia) was introduced in the Income Tax Act, by the Finance Act, 2004 with effect from 1-4-2005 with a view to augment the revenue through the mechanism of deduction of Tax at source. This provision was brought on the statute to disallow the claim of even genuine and admissible expenses of the assessee under the head ‘Income from Business and Profession’ in case the assessee does not deduct Tax at Source [TDS] on such expenses. The default in deduction of TDS would result in disallowance of expenditure on which such TDS was deductible. While enacting the above provision the legislature stated that it proposed to extend the provisions of section 40(a)(i) to payments of interest, commission or brokerage, fees for professional services or fees for technical services to residents, and payments to a resident contractor or sub-contractor for carrying out any work (including supply of labour for carrying out any work), on which tax has not been deducted or after deduction, has not been paid before the expiry of the time prescribed under sub-section(1) of section 200 and in accordance with the other provisions of Chapter XVII-B. …in order to ensure compliance with the TDS provisions. In 2012 the majority view of a Special Bench of the Income Tax Appellate Tribunal 1had given a conclusion that provisions of section 40(a)(ia) are applicable only to the amounts of expenditure which are payable as on the date 31st March of every year and it cannot be invoked to disallow expenditure which has been actually paid during the previous year,
without deduction of TDS. This view was overruled by the High Court of Calcutta in the case of Crescent Export Syndicate2. A view similar to that of the Calcutta High Court was taken by the Punjab & Haryana High Court as well as the Madras High Court3. The Allahabad High Court in the case of Vector Shipping Services Pvt. Ltd 4however approved the decision of the Special Bench in the case of Merilyn Shipping & Transports
The Case of Palam Gas Agencies Before the Supreme Court The assessee in the case on hand had made a sub-contract with three persons towards freight within the meaning of Section 194C of the Act and, therefore, he was liable to deduct tax at source from the payment of Rs. 20,97,689/-. On account of his failure to do so the said freight expenses were disallowed by the Assessing Officer as per the provisions of Section 40(a)(ia) of the Act. The assessee argued that that since the amounts had already been paid, it can straightaway be concluded, that the such amounts would not be covered within the mischief of Section 40(a) (ia), that Section 40(a)(ia) would apply only when the amount remains ‘payable’ at the end of the year. Against the order of the Assessing Officer, the assessee preferred an appeal before the Commissioner of Income Tax (Appeals), Shimla who vide its order dated August 17, 2012 upheld the order dated November 30, 2011. The matter thereafter came up in appeal before the Income Tax Appellate Tribunal (for short ‘ITAT’) which too met with the same fate. In further appeal to the High Court under Section 260A of the Income Tax Act, the outcome remained unchanged as the High Court of Himachal Pradesh also dismissed the appeal affirming the order of the ITAT.
Observations of SC When the entire scheme of obligation to deduct the Tax at Source and paying it over to the Central Government is read holistically, it cannot be held that the word ‘payable’ occurring in Section 40(a)(ia) refers to only those cases where the amount is yet to be
paid and does not cover the cases where the amount is actually paid. If the provision is interpreted in the manner suggested by the appellant herein, then even when it is found that a person, like the appellant, has violated the provisions of Chapter XVIIB (or specifically Sections 194C and 200 in the instant case), he would still go scot free, without suffering the consequences of such monetary default in spite of specific provisions laying down these consequences. Insofar as judgment of the Allahabad High Court is concerned, a reading thereof would reflect that the High Court, after noticing the fact that since the amounts had already been paid, it straightaway concluded, without any discussion, that Section 40(a)(ia) would apply only when the amount is ‘payable’ and dismissed the appeal of the Department stating that the question of law framed did not arise for consideration. No doubt, the Special Leave Petition there against was dismissed by this Court in limine. However, that would not amount to confirming the view of the Allahabad High Court (See V.M. Salgaocar & Bros. (P) Ltd. v. Commissioner of Income Tax, [2000] 243 ITR 383 and Supreme Court Employees Welfare Association v. Union of India, [1989] 4 SCC 187. In view of the aforesaid discussion, the Honorable Supreme Court held that the view taken by the High Courts of Punjab & Haryana, Madras and Calcutta is the correct view and the judgment of the Allahabad High Court in CIT v. Vector Shipping Services (P) Ltd., [2013] 357 ITR 642 did not decide the question of law correctly. Thus, the judgment of the Allahabad High Court was overruled by the Honorable Supreme Court.
Comments The elaborate judgment of the Supreme Court has in this decision analyzed the provisions of section 40 (a)(ia) and set at rest a controversy which should not have arisen in the first place. Gayatri Sridharan Principal Associate Direct Taxes M/s Lakshmikumaran& Sridharan, Attorneys
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ISRAEL Henriette Fuchs Partner, Chair of the International Tax Group Pearl Cohen Zedek Latzer Baratz +972-3-607-3769 https://www.pearlcohen.com/ HFuchs@PearlCohen.com
Bio Henriette Fuchs is a Partner at Pearl Cohen’s Tel Aviv office and Chair of the International Tax Group. She has a strong existing practice, based on over 20 years of experience, providing comprehensive tax guidance to international companies with commercial activities in Israel, and Israeli companies with international activities, including complex matters relating to direct and indirect taxation.
Henriette’s unique expertise regarding cross-border transactions, covers all tax aspects relevant for incoming international investment, from IP and technology related tax structuring to large infrastructure projects, as well as complex outbound investment and financing structures. Further, Henriette is active in the framework of the tax committee of the Business and Industry
Advisory Committee (BIAC) reporting to the Israel Manufacturers Association in relation to OECD and its advancing plans in the field of international tax planning. Henriette and the International tax group, provide regular updates regarding tax law and developments in Israel, to the International Bureau for Fiscal Documentation and Tax Analysts.
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