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 Deloitte LuxembourgLuxembourg has transposed the EU's Anti-Tax Avoidance Directive (ATAD) into its domestic law, with the rules applying for financial years starting on or after January 1 2019.
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Sponsored by Deloitte SwitzerlandSwitzerland's Tax Reform and AHV Financing Bill (TRAF, formerly known as Swiss Tax Reform 17 and Swiss Corporate Tax Reform III) will officially be subject to a referendum, as a largely left wing alliance made up of junior green and socialist parties has secured more than 50,000 signatures against the proposed law. The public vote is now scheduled for May 19 2019.
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