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 Dhruva AdvisorsUnder Indian law, capital gains on the transfer of shares of an Indian company are taxable in India. However, under a few treaties, including Mauritius, the right to tax such gains has been ceded by India in favour of the seller's country of residence. -
Sponsored by MachadoProvisional Measure 651/2014, enacted in July 2014 (MP 651/2014), re-established the Brazilian Special Regime for the Reinstatement of Taxes for Exporters (REINTEGRA).
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Sponsored by PwCAccording to the Mexican Income Tax Law (MITL), the expenses made with foreign related parties, on a pro-rata basis, are not deductible. However, a recent decision from the country’s Supreme Court means those expenses may now be deductible in certain circumstances.
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