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 Deloitte NorwayThe evaluation of the GAAR is following up on one of the recommendations put forward by the Scheel tax commission. -
Sponsored by Deloitte NorwayThe Supreme Court in Odfjell Rig (case Rt-2015-1360) concluded that the limited activities carried out onshore were not sufficient to create the taxable nexus to Norway that would be necessary for tax to apply to the income deriving from a bareboat charter.
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Sponsored by Dhruva AdvisorsThe government has released proposals for public comments in which it has set out the manner in which exemptions and deductions will be phased out.
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