Issues
ITR has partnered with leading Swiss tax specialists to consider the most pressing taxation issues facing the country.
With the M&A market booming, ITR has partnered with correspondents from firms around the globe to provide a guide to the deal structures being employed and tax authorities' responses.
ITR has partnered with global TP leaders from Deloitte to discuss transfer pricing controversy around the globe, and to share advice on how to navigate an increasingly uncertain and risky TP landscape.
As Latin American countries increasingly align with the OECD, transfer pricing (TP) remains a hot topic, while jurisdictions continue to introduce tax reforms in the wake of COVID-19. ITR’s correspondents offer an overview.
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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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