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 Garrigues SpainThe mere holding of a Spanish residential property by a non-tax resident gives rise to tax on an annual basis, regardless of whether the property is held directly by the individual or through a corporate structure. -
Sponsored by Hager & PartnersOn 28 December 2018, the Italian government published Legislative Decree No. 142, transposing the European Union's Anti-Tax Avoidance Directive (2016/1164) into Italian legislation. The new set of provisions will be effective from the fiscal year following December 31 2018. The decree will aim to tackle tax avoidance practices related to interest deduction, exit tax, rules on foreign controlled companies, a definition of financial intermediaries, and hybrid mismatches, all of which are explored below.
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Sponsored by NeraThis article describes the challenges that the digital transformation of the economy poses for transfer pricing. In the next article of the series, it will show how these interdependencies can be translated into new transfer pricing models.
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