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 BrazilBrazilian tax authorities have said that no relief should be granted for withholding tax on payment to foreign not-for-profit organisations under the Brazil-France double tax agreement (DTA). -
Sponsored by Eurofast CroatiaTax incentives in Croatia for research and development (R&D) projects were granted between 2007 and 2014 based on Articles 111 a. to 111 f. of the Act on Scientific Activity and Higher Education. However, the European Union issued Commission Regulation (EU) No. 651/2014 in June 2014, concerning certain categories of state aid; this used significantly different terminology, definitions, and requirements, and rendered the abovementioned articles invalid. Croatian entrepreneurs found themselves in something of a vacuum for more than three years, awaiting a new legal framework for R&D incentives, as the relevant tax incentive had been abolished on January 1 2015. In July 2018, the Croatian Parliament adopted and published the Act on State Aid for Research and Development Projects, which the government had submitted in January 2018.
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Sponsored by Hager & PartnersIn general terms, inherence can be described as the relationship between the cost and the enterprise, where the cost has a specific relevance to the determination of income; this is a result of its connection not to a specific revenue, but rather to an activity potentially able to produce income. Based on this assumption, in order to consider a cost deductible (i.e. inherent), the taxpayer is required to demonstrate clearly the connection with the activity, providing the tax authority with "sufficient" documentation.
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