Portugal has historically favoured source-based taxation on passive income, which has been coupled with stringent documentation requirements to claim the application of tax treaties (the so-called RFI forms). The Portuguese tax authorities have recently published a new set of procedural forms, this time to apply the transitional regime under the interest and royalties directive (council directive 2003/49/EC). Those developments provide a good pretext to outline the current state of play concerning outbound interest and royalty payments.
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Audifina, the sixth-largest firm of its kind in Lithuania, will bring a 90-strong team with offices in Vilnius and Kaunas to RSM’s international platform
The future chief tax officer will be judged not only on compliance, but on their ability to harness data, technology and AI to support strategic decision-making
Ryosuke Takemura, OECD policy adviser, countered that the organisation’s role is ‘not to solve these issues one by one’ but to prevent tax disputes in general