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 KPMG ChinaThe Chinese State Administration of Taxation (SAT) has introduced two important new circulars to clarify the application of relief under China's double tax agreements (DTAs). -
Sponsored by Deloitte MexicoA recent court ruling in Mexico has enabled the tax authorities to dive deeper into taxpayer affairs to determine whether transactions have real substance. Carlos Ramírez & Víctor Masón of Deloitte Mexico explain why taxpayers should take note of this judgment.
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Sponsored by Hager & PartnersTen years after the Circular Letter n 1/2008 was issued, on December 1 2017 the Italian tax police (Guardia di finanza) released the updated version of its operational manual for tackling tax evasion and fraud (i.e. Circular n 1/2018). This new document includes – as in the past – a section dedicated to transfer pricing (volume III, part V).
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