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Postponement of Country-by-Country reporting and (potential) unconstitutionality

This note concerns Country-by-Country Reporting (“CbCR”), particularly the Portuguese regime, the postponement of reporting duties, potential legal changes due to the EU Directive regarding CbCR and, lastly, the recent decision by the French Conseil Constitutionnel that decided for the unconstitutionality of the public part of the French CbCR regime. Such public nature of CbCR is also being pursued by the European Union. This regime is one...
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An Overview on… Company Incorporation

According to Portuguese Business Law, any person performing commercial activities shall set up and legally incorporate a commercial company. Commercial companies are legal entities performing an economic activity and, therefore, with an inherent profitable goal. When a company lacks a lucrative purpose, law denominates them as a civil society.
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International Double Taxation in Portugal (2016)

Globalization has fostered international trade and enterprises have expanded their activities at a fast rate through the entire world. Multinational Enterprises (MNEs) face a challenge, not uniquely in the market but, as well, by means of taxation. Since their economic transactions have effects in different jurisdictions, the same income may be taxed more than once: international juridical or economical double taxation.
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Madeira's Internacional Business Center (2016)

Madeira’s free trade zone encompasses a special tax regime, which has been authorized by the European Commission as legal regional State Aid. It offers companies incorporated therein or companies that will be incorporated until December 2020, as well as to their shareholders, plentiful fiscal benefits, which may be enjoyed until December 2027. Insofar as certain economic substance requirements are met, these corporations may enjoy a 5% c...
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Concerning the Apple case

Taxation of multinational enterprises is at a cross-roads, following cases such as Apple, Starbucks or Fiat . The European Commission, though State Aid investigations, has been tackling what it perceives as undue tax benefits granted by advance tax rulings.
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