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 Deloitte SwitzerlandSwitzerland is phasing out principal company and finance branch rulings as part of broader tax reform. -
Sponsored by KPMG ChinaOn August 31 2018, the revised IIT Law was passed by China's Parliament, the National People's Congress (NPC). The revised law will come into full effect from January 1 2019. In advance of this, revised IIT standard personal deductions and tax rates tables have applied from October 1 2018. Following on from this, on October 20 2018 the Ministry of Finance (MOF) and the State Administration of Taxation (SAT), released draft IIT Law implementation rules, as well as the draft guidance on itemised deductions thresholds, both for public consultation. The consultation period has now ended but the final rules are still to be released.
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Sponsored by Hager & PartnersA ruling issued on November 2 2018 by the Central Revenue has provided clarification regarding the application of the VAT regime to transfer pricing (TP) year-end adjustments occurring between related companies belonging to the same multinational group (group).
