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The tax treaties that Mexico has renegotiated recently give a good overview of where it is positioned on the taxation of capital gains, believe Carlos Gradwohl and Claudia Solano of PricewaterhouseCoopers

Now is a popular time to buy distressed loans cheaply in Ukraine. However, there are many tax issues to consider, such as where to locate the corporate entities used to make the purchases, explains Igor Chufarov of Ernst & Young

The object of a bond tax exemption in Japan appears to be to expand significantly the global market for yen-denominated debt and debt-financing for Japanese issuers, reveal Michael Shikuma, Christopher Wells and Takeo Mizutani of White & Case

Portugal has won a case against the European Commission in the European Court of Justice over the taxation of mortgage interest.

Reference for a preliminary ruling Directive 90/435/EEC Concept of withholding tax Application of a levy of 5% at the time of distribution of dividends and of the refund of the adjustment surtax by an Italian subsidiary to its parent company established in the Netherlands, pursuant to a bilateral convention. The European Court of Justice (ECJ) provisionally backed Italy's withholding tax on the cross-border refund of a surtax on dividend payments, but referred pivotal decisions in the case such as final classification of the refund back to the domestic court.

Paulo Núncio Tiago Cassiano Neves On June 17 2010 the European Court of Justice (ECJ) issued its judgment in Commission v Portugal (C-105/08), regarding the infringement procedure on the potential discriminatory tax treatment of outbound interest payments to EU/EEA based financial institutions. This case raises the issue of the compatibility of a withholding tax on gross interest paid to non-resident financial institutions, while in a domestic situation taxation is levied on a net basis.

Diego Rodríguez The Spanish Corporate Income Tax (CIT) Act contemplates a full exemption for dividends and capital gains obtained by a Spanish company from its foreign subsidiaries. Generally speaking, the conditions to take the exemption are three-fold: A minimum 5% ownership interest must be held uninterruptedly in the subsidiary for at least one year (the minimum ownership interest threshold may be also met if the Spanish company has applied for the ETVE regime for foreign-securities holding companies and the acquisition cost of the ownership interest in the subsidiary is higher than €6 million ($7.2 million); The subsidiary must be subject to an identical or similar tax to the Spanish CIT; And the subsidiary must carry on business activities outside Spain.

Bob van der Made The European Commission has missed a self-imposed deadline to produce a formal reaction to former Commissioner Monti's suggestions for re-launching the single market and the role of taxation therein.

Monika Dziedzic Many older double tax treaties concluded by Poland are now being renegotiated. The amendments concern mainly treaties concluded in 1970s and 1980s, but there was also a few treaties concluded in 1990s or even in the present decade that are still subject to verification. Recently, Poland has changed treaties with Finland, Norway, Switzerland, and Denmark, but some other significant treaties are also planned to be changed such as the treaty with Belgium, the Czech Republic, the US, Spain, Malaysia, Malta, Cyprus and Canada.

Elena Kostovska FYR Macedonia and Estonia further strengthened their relations by signing an income tax treaty on November 20 2008. The treaty was ratified by both States during April 2009 and entered into force on 21 May 2009. Its effective date is January 1 2010, whereas it is applicable for a minimum period of five years. The treaty with Estonia is generally in line with the OECD convention with only a few variations.