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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 KPMG China
    At 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.
  • Sponsored by EY Romania
    In recent years, due to the fairly low percentage of tax collection, the Romanian tax authorities (RTA) have increased pressure on revenue collection by various means.
  • Sponsored by PwC Chile
    As a rule, remuneration for services – digital or otherwise – rendered by a non-resident non-domiciled in Chile to Chilean taxpayers are subject to a withholding tax, with rates of up to 35% over the full paid amount depending on the type of service.