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 Garrigues PortugalThe Portuguese tax authorities recently published three rulings covering taxation of income derived from foreign fiduciary structures by resident individuals. -
Sponsored by Deloitte SwitzerlandThe Swiss Corporate Tax Reform 17 (STR 17) remains an urgent task for the Swiss federal government, and the finance minister has provided an update on the timeline for implementation.
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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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