May 2009

Main

Firms show sparkle in tax planning

Emergency budget improves Ireland's IP regime

Permanent establishment on the Norwegian continental shelf: a never ending story

VAT deduction on the purchases of fuel to vehicles

State of play on outbound interest and royalty payments

Transfer pricing documentation

Anti-tax avoidance measures

Proposed tax changes to facilitate economic recovery

EU tax matters in recent Spanish case law

Tax deduction for final losses in subsidiaries within the EEA

VAT rate increase for the benefit of the IV (disability insurance)

Temporary regulations close repatriation loophole

IRS clarifies term under the US-Belgium treaty

DLA expands tax practice

Bird & Bird gains a partner

Ex-Deloitte boss gets government role

Steinberg heads back to private practice

Ernst & Young strengthens in financial services

VMW Taxand takes three from Deloitte

Dolan leaves Merrill Lynch for Shearman & Sterling

Skadden gains two partners

BMR Advisors adds three new partners

Cragus hires former tax director

Ashurst promotes one

Tax havens come under more scrutiny from world leaders

Editorial

Tax relief

Getting transfer pricing right in the recession and beyond

Q&A

How APAs fit into today's regulatory landscape

Owens resists blaming tax havens for economic downturn

Companies get help with business rates

European Commission leaves multinationals waiting nervously

World leaders keep their word and crack down on tax havens

Pakistan's ACCA proposes corporate tax changes

Ways and Means staffer discounts reform

Hay stresses need for closer cooperation

Tax guidelines boost Islamic finance in France

Exemption reforms are timely benefit

Court strives for balance on economic substance

Whiting gets his point across

New incentives for oil and gas industry

Tax controversy and intragroup financial transactions

Revolutionary VAT changes for taxation of services from 2010

Changes to foreign assets reporting

Tax authorities lose appeal in beneficial ownership case

Exemption for select credit guarantee institutions announced

Spanish structuring and back-to-back financing developments

Depreciation allowances of production investments to double for two years

Local business tax to be replaced by energy tax framework

Interest limitation and loss forfeiture to be relaxed

Ruling on withholding tax on overseas salary payments

Ireland ranks highly as a location for business

Tax authorities issue circular on IP exemption regime

Decree offers repatriation benefits

Tax policy work programme released

International Correspondents

Features

New Analysis

Tax Relief

Special Features

Editorial

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Sponsored by Garrigues Portugal

State of play on outbound interest and royalty payments

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.

Tiago Cassiano Neves, April 30, 2009