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 ChinaAgainst a backdrop of continuing China-US trade tensions, Chinese President Xi Jinping on April 10, at the Bo'ao Forum for Asia, announced a 'four-point plan' for the further liberalisation of rules governing foreign investment in, and trade with, China. -
Sponsored by Dhruva AdvisorsIndian law provides that the dividends paid by domestic companies to their shareholders are liable to a dividend distribution tax at the company level. As a corollary, such dividends are exempt in the hands of shareholders, subject to certain exclusions.
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Sponsored by Fenwick & WestThe Tax Cuts and Jobs Act (2017 Act) overturned Grecian Magnesite v Commissioner, which held that the sale by a foreign person of its interest in a partnership engaged in a US trade or business was not subject to US tax.
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