Brazil: Tax Haven Jurisdictions – Haven Or Hell?

I. Introduction
Although internationally adopted, the expression “tax haven” has not been used in the Brazilian applicable legislation. Brazilian regulatory authorities do not like offshore jurisdictions, considered as “tax havens”, because they believe that these jurisdictions have been misused in general with the specific purpose of  (i) avoiding the payment of local taxes and/or (ii) not disclosing the identity of the true beneficiaries of the assets (which could be Brazilian residents pretending to be foreign […]

By |January 8th, 2013|

Mexico Enters Into New Tax Treaties

On January 1, 2013, Mexico will enter into new income tax treaties with Lithuania and Ukraine. Once these treaties come into force, Mexico will have a tax treaty network with 51 countries.

In negotiating and executing the tax treaties, Mexico has been using the OECD Model Tax Convention on Income and on Capital, incorporating some features from the UN Model Tax Convention (Article 5—period for converting a construction site into a permanent establishment; Article 15—independent […]

By |January 2nd, 2013|

The New Double Tax Treaty Between Turkey And Germany

A. Introduction
On 1 August 2012, a new Agreement between the Federal Republic of Germany and the Republic of Turkey for the Avoidance of Double Taxation and of Tax Evasion with respect to taxes on Income (the “Treaty”) came into force with retroactive effect as of 1 January 2011. It replaced its predecessor treaty which was terminated by Germany on 21 July 2009 and ceased to apply as of 1 January 2011. From a German […]

By |December 17th, 2012|