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 Fenwick & WestThe new US tax law's base erosion and anti-abuse minimum tax (BEAT) will have a substantial impact on inbound taxpayers. -
Sponsored by Garrigues SpainAs is known, and as has been highlighted on these same pages in the past, the European Commission has in the last years deployed intense activity at the review, under EU state aid rules, of national laws (and individual rulings) regulating the direct taxation of companies.
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Sponsored by PwC ChileThe Chilean IRS issued Circular Letter No 57 on December 7 2017 regarding the concept of permanent establishment (PE) for purposes of obtaining a Chilean identification number when non-resident, non-domiciled individuals or legal entities initiate business activities in Chile.
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