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 ChinaOn August 31 2018, the revised IIT Law was passed by China's Parliament, the National People's Congress (NPC). The revised law will come into full effect from January 1 2019. In advance of this, revised IIT standard personal deductions and tax rates tables have applied from October 1 2018. Following on from this, on October 20 2018 the Ministry of Finance (MOF) and the State Administration of Taxation (SAT), released draft IIT Law implementation rules, as well as the draft guidance on itemised deductions thresholds, both for public consultation. The consultation period has now ended but the final rules are still to be released.
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Sponsored by PwC ChileThe tax authority under a formal and strict application of such criterion has rejected expenses that were perfectly reasonable from a business perspective. -
Sponsored by KPMG RussiaIn April 2018 the Federal Tax Service of Russia issued a letter (Letter No. CA-4-9/8285@) containing guidelines for lower tax authorities on how to use the beneficial ownership concept when applying treaty benefits in Russia.
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