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 Hong KongIn recent years, there have been various accounting changes which have had significant tax implications on how certain items are accounted for and potentially taxed. The two main changes in Hong Kong have been HKFRS 9 (affecting financial instruments) and HKFRS 16 (leases). -
Sponsored by KPMG ChinaAt an executive meeting of China's State Council on July 23 2018, Premier Li Keqiang announced that the country would expand the scope of the 75% corporate income tax (CIT) super deduction for eligible research and development (R&D) expenses to cover all resident enterprises. This super deduction rate currently applies to defined science and technology-related small and medium-sized enterprises (SMEs), while other enterprises can obtain a 50% super deduction. The announced changes will abolish the 50% super deduction incentive. The details of the expanded incentive are still pending, and it remains to be seen whether the increased super deduction rate can be applied retroactively and whether the scope of deductible expenses will be expanded further. This improvement to the super deduction follows the enhancement of the incentive in June's Cai Shui (Circular) 64, to cover R&D work outsourced by Chinese enterprises to foreign providers.
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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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