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 PwC BrazilThe federal Brazilian tax authorities (RFB) published a declaratory act regarding the withholding tax on payments abroad for a license to distribute or commercialise software. -
Sponsored by KPMG ChinaIn the final days of 2017, the Chinese authorities set out a series of new incentives and improved tax treatments with a view to fostering both greater inbound and outbound investment in 2018. The Chinese Finance Minister, Mr Xiao Jie, also set out his plan of broader reforms for the medium term.
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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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