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 PwC BrazilThe Brazilian tax authorities have provided guidance on the application of the reduced 0% income withholding tax rate on international charter leasing payments. -
Sponsored by Garrigues SpainSpain levies a net wealth tax on the net assets of individuals for the purposes of which any individual owning assets located, or rights which can be exercised, in a Spanish territory is classed as a taxable person by virtue of an in rem obligation.
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Sponsored by Eurofast AlbaniaOn June 8 2018, Kosovo and Austria signed the Convention for Elimination of Double Taxation with the purpose of developing their economic relationship and enhancing their co-operation in tax matters. On July 27 2018, Kosovo ratified the treaty; thus it will be effective from next year.
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