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Generally, a gain realised by a non-resident of Canada on the sale of shares of a corporation that derive more than 50% of their value from Canadian real property (CRP), being real properties or resource properties situated in Canada, at any time in the 60 months preceding the sale is subject to tax in Canada. Such shares are known as "taxable Canadian property" (TCP). Exceptions exist for holdings of shares listed on a designated stock exchange where the holder owns less than 25% of any class of shares of the issuer and under the provisions of certain tax treaties. On May 1 2017, the Canada Revenue Agency (CRA) released a Technical Interpretation (TI) (2015-0624511I7) describing the approach that should be followed to make the 50% determination if the property of the corporation (Parentco) includes shares or debt of a wholly-owned subsidiary corporation (Subco). Although the TI addresses a prior version of the TCP definition, the comments appear to be applicable to the current definition, which employs essentially identical language relating to derivation of value.

The concept of corporate legal migration, i.e. the change of domicile of any legal entity, is not included in the Chilean tax law. Thus, its effects depend on the concept of legal residency given by the country from which the company migrates, as well as by the country to which the company moves to.

Read this month's special features on Tax technology and transformation and Mexico

On June 27 2017, the Prime Minister of Bosnia and Herzegovina adopted a decision ratifying the income tax treaty between Bosnia and Herzegovina and Romania, which was signed on December 6 2016. When it becomes effective (pending Romania's ratification), the treaty will replace the former Yugoslavia–Romania income and capital tax treaty of 1986.

India's Supreme Court has reinforced its decision in the Formula One permanent establishment (PE) case and further clarified the application of service and agency PE rules in a recent case.

Every year the European Commission adopts its work programme setting out the list of actions it will take in the year ahead. The work programme informs the public and the EU's co-legislators (Council of the EU and European Parliament) of the Commission's political commitments to present new initiatives, withdraw pending proposals and review existing EU legislation.

Questions are being asked about how much influence tax advisers have on the use of tax havens The Big 4 accounting firms have been slammed by a new report on tax havens, as the international debate following the release of the Paradise Papers widens and the EU presses for action against tax advisers.

Following public consultation on the draft bill earlier in the year, the final version of the 2017 Taxation Laws Amendment Bill (TLAB) is now before Parliament.

The Minister of Finance (MoF) enacted MoF Regulation No. 165/PMK.03/2017 on November 20 2017, concerning the second amendment to MoF Regulation No. 118/PMK.03/2016 regarding the implementation of Law No. 11 of 2006 concerning the tax amnesty (MoF Regulation 165). The MoF Regulation 165 provides amnesty for those who did not participate in the tax amnesty programme and those who participated but have not reported all of their assets.

The Maltese notional interest deduction rules (the rules) were published on October 5 2017, further to an announcement made in the previous 2017 budget. Traditionally, debt financing in Malta has been regarded as more efficient from a tax perspective due to the deductibility against chargeable income of finance costs incurred by companies upon the granting of loans. The main objective of the rules is to approximate the manner in which cost of equity and cost of debt are treated from a tax perspective. The rules provide certain undertakings with the possibility of deducting interest they are deemed to have incurred on equity.