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 Eurofast AlbaniaOn June 8 2018, Kosovo and Austria signed the Convention for Elimination of Double Taxation with the purpose of developing their economic relationship and enhancing their co-operation in tax matters. On July 27 2018, Kosovo ratified the treaty; thus it will be effective from next year.
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Sponsored by MathesonOn October 9 2018, Ireland's Minister for Finance, Public Expenditure and Reform Paschal Donohoe announced budget 2019. On October 18 2018, the draft legislation to implement the budget was published. In furtherance of Ireland's obligations under the EU Anti-Tax Avoidance Directive (ATAD), Donohoe announced the introduction of a new controlled foreign companies (CFC) regime and an ATAD-compliant exit charge. The exit charge took effect from October 10 2018 and the CFC rules will apply to accounting periods beginning on or after January 1 2019.
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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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