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Sponsored by PwC BrazilSince June 2008, when a broadened definition of low-tax jurisdictions (tax havens) was introduced by the authorities, taxpayers have been eagerly awaiting the enactment of an updated black list of tax haven jurisdictions for tax and transfer pricing purposes. The latest version of the black list was issued in August 2002. -
Sponsored by Garrigues PortugalA country's tax policy is reflected in its domestic tax legislation as well as its tax treaty positions.
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Sponsored by Garrigues PortugalPortugal 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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