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 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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