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 PwC BrazilOn December 29 2017, Law 13,586/2017 (dated December 28 2017) was published providing for the conversion of Provisionary Measure 795/2017 (PM 795/2017) into law. -
Sponsored by MDDPRevolutionary modifications in transfer pricing (TP) regulations, introduced by the Corporate Income Tax (CIT) law amendment valid since January 1 2017, may be followed by more changes binding from 2018.
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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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