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 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 Garrigues SpainSpain levies a net wealth tax on the net assets of individuals for the purposes of which any individual owning assets located, or rights which can be exercised, in a Spanish territory is classed as a taxable person by virtue of an in rem obligation.
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Sponsored by PwC BrazilThe federal Brazilian tax authority (RFB) has confirmed that off-the-shelf software acquired for personal use should not be subject to withholding tax.
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