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 KPMG Hong KongHong Kong and Australia have successfully concluded negotiations on a free trade agreement (FTA) and a new investment agreement (IA) on November 15 2018. The FTA and the IA negotiations between Hong Kong and Australia commenced in May 2017, bringing the 18-month negotiation to a close. -
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 EY in GreeceThe case at hand concerned an appeal of an individual, who is a tax resident of the UK, who requested annulment of the special solidarity tax assessment imposed by the Greek tax authorities on income realised in the 2015 tax year
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