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 ChinaOn June 29 2018, China's Parliament, the National People's Congress (NPC), released the full text of proposed amendments to China's individual income tax (IIT) law (draft IIT bill). Public comments were sought up until July 28 2018. The upshot of the proposed changes is to reduce the tax burden on lower earners, reduce the relative preferences for foreign nationals under the existing IIT law, give greater recognition to personal circumstances and expenses in the IIT calculation, and introduce anti-avoidance provisions. The changes to personal deductions and tax brackets would take effect in part from October 2018, and the rest of the changes from January 2019. -
Sponsored by KPMG Hong KongIn July 2018, transfer pricing (TP) legislation – Inland Revenue (Amendment) (No 6) Bill 2017 (BEPS Bill) – was passed in Hong Kong. This represents one of the biggest changes to Hong Kong tax in recent years. Many of the provisions within the BEPS Bill will have retrospective effect from the year of assessment 2018/19. The notable amendments to the initial proposal are:
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Sponsored by DLA Piper AustraliaOn June 21 2018, the Australian Taxation Office (ATO) released updated guidelines on the corporate residency test in Taxation Ruling TR 2018/5 and Draft Practical Compliance Guidelines PCG 2018/D3.
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