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 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. -
Sponsored by KPMG USOn January 12 2018, the Internal Revenue Service (IRS) released five directives from the large business and international (LB&I) division.
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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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