International Updates
On December 10 2018, Portugal published Notice 144/2018 in the Official Gazette, announcing the new income tax treaty with Montenegro.
Under the 60-day rule in Cyprus, individuals are considered tax residents of Cyprus and benefit from the island's tax regime.
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 NeraIn a previous article in this series, we described the necessity of rethinking transactional net margin method (TNMM) studies and enhancing them with economic analysis. NERA Economic Consulting Managing Director Yves Hervé and Associate Director Philip de Homont describe how economic adjustments can be used to improve the quality of benchmarking analyses. -
Sponsored by PwC BrazilOn 28 August 2018, Decree 9.482 was published, enacting amendments to the protocol to the convention between Brazil and Argentina.
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Sponsored by PwCOn September 12 2018, European Commission President Jean-Claude Juncker delivered his 2018 State of the European Union (EU) address at the European Parliament. Accompanying his speech were a number of more detailed policy documents, the most important of which was the Letter of Intent from Juncker and First VP Frans Timmermans to the presidents of the European Parliament and the Austrian EU Council presidency.
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