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 DLA Piper AustraliaThere have been a number of important Australian tax developments recently that affect offshore businesses/investors and their inbound investments into Australia. -
Sponsored by Dhruva AdvisorsRecently, the Income Tax Appellate Tribunal gave an important judgement regarding the creation of and attribution of profits to an agency permanent establishment (Agency PE) – Daikin Industries v ACIT ('ITA No 1623 of 2015 [New Delhi Income Tax Appellate Tribunal, May 28 2018]').
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Sponsored by MDDPOn July 1 2018, the Polish VAT Act of 11/03 2004 is to be amended by a new regulation introducing a voluntary split payment as a method of payment of purchase invoices – from the perspective of taxpayers – and as a new tool to combat VAT fraud – from the perspective of tax authorities. However, from the perspective of VAT taxpayers the new mechanism may bring more radical changes than expected in some areas.
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