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 Deloitte LuxembourgOn October 2 2018, the EU Council agreed to adopt several proposals from the European Commission to reform the EU VAT system. These proposals included four 'quick fixes' to the prevailing regime that will apply to improve the functioning of the existing VAT system, pending the introduction of the 'definitive' VAT system that is still the subject of continuing discussion.
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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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Sponsored by Deloitte SwitzerlandSwitzerland is phasing out principal company and finance branch rulings as part of broader tax reform.
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