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 Russell McVeaghThe New Zealand Court of Appeal has overturned a High Court decision allowing a New Zealand taxpayer foreign tax credits for tax spared (under Chinese law) to Chinese companies treated as controlled foreign companies under New Zealand's CFC rules. -
Sponsored by Dhruva AdvisorsThe Apex Court in a recent judgment (Civil Appeal number 2013 of 2014) held that no service tax should apply on expenditures recovered as reimbursements before May 14 2015.
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Sponsored by Garrigues PortugalThe option for VAT taxation of the supply of Portuguese real estate has recently been characterised by uncertainty, and the latest European ruling hopes to clarify matters.
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