Withholding Taxes on Dividends, Services and Capital: Searching for a comparability éclairé

Author Francisco Cabral Matos
Supervisor Ana Paula Dourado

Table of Contents
List of Abbreviations
Executive Summary
Main Findings
1 Introduction
2 Identifying the different comparison tests
2.1 Starting point: determining comparability
2.2 Withholding tax on dividends
2.3 Withholding tax on services
2.4 Withholding tax on interest
3 Reconciling tests for withholding tax on dividend, service and capital
3.1 In search for legal certainty
3.2 Reconciling the different tests: is it feasible?
3.3 Reconciling the different tests: in practice
4 Conclusions
4.1 Application of a systematic approach
4.2 Selection of the comparability standard
4.3 The role of the ECJ and of the national courts
4.4 Trends for the application of withholding taxes in the future
Bibliography
List of Cases

Tax on Inbound Investment 2011 - Portugal section

Dear all,

In case you are advising on corporate transactions, please consider the opportunities arising in Portugal. For some introductory information on the most relevant features of the Portuguese tax system regarding acquisitions, post-acquisition planning and sale of holdings, check here the Portuguese section of the 'Tax on Inbound Investment 2011', contributed by my law firm.

Any further queries, just ask!

Cheers,
Francisco
fcm@vda.pt

EU tax news (PwC) - Issue 2011-004

EU tax news is a newsletter prepared by PwC and covers (i) relevant ECJ case law, (ii) national court cases and decisions and (iii) EU policy initiatives related to EU direct tax law and state aid.

Check issue 2011-004 here.

IFA Congress 2011

IFA Congress (2011) will be held in Paris, from 11 September 2011 - 16 September 2011.

The most relevant topics in the agenda are the Cross-border business restructuring and Key practical issues to eliminate double taxation of business income.

For more information, check the official website.