International Updates
Under the 60-day rule in Cyprus, individuals are considered tax residents of Cyprus and benefit from the island's tax regime.
On December 10 2018, Portugal published Notice 144/2018 in the Official Gazette, announcing the new income tax treaty with Montenegro.
Russian legal entities that make capital gains from the sale of shares are eligible for a 0% tax rate, yet the criteria for satisfying this arrangement may not always be so simple.
Canada's Revenue Agency (CRA) confirmed in a recent technical interpretation (2017-071330117) that Canadian withholding tax can apply to the accrued (but unpaid) interest on a debt owed by a Canadian resident to a non-resident when the debt is assumed by another entity and such an assumption constitutes a "novation" of the debt obligation for purposes of the applicable commercial law.
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Sponsored by Webber WentzelSouth Africa's Supreme Court of Appeal (SCA) handed down an important judgment on the doctrine of simulation, or substance over form, on November 9 2018, putting to rest some significant confusion created by an earlier judgment of the Gauteng Tax Court. -
Sponsored by Eurofast CroatiaCroatia and Japan celebrated their 25th anniversary of diplomatic relations in 2018. This milestone was further marked with the signing of an agreement on double taxation avoidance (DTA) on October 19 2018. The official document was concluded in English and is yet to be ratified and enforced by the respective states.
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Sponsored by GNV ConsultingOn December 19 2018, Indonesia's Minister of Finance (MoF) issued regulation No. 167/PMK.03/2018 (PMK-167) regarding the provision of food and beverages to all employees, and compensation in the form of benefit in kind (BIK) in certain regions that can be deducted from gross income. PMK-167 replaces the previous regulation: MoF Regulation No. 83/PMK.03/2009 (PMK-83). The benefit in kind that can be deducted from the employer's gross income are as follows.
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