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 ChileThe tax authority under a formal and strict application of such criterion has rejected expenses that were perfectly reasonable from a business perspective. -
Sponsored by KPMG Hong KongOn November 2 2018, Hong Kong's new research and development (R&D) regime was enacted and applies to eligible expenditure incurred on or after April 1 2018.
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Sponsored by PwC BrazilThe federal Brazilian tax authority (RFB) has confirmed that off-the-shelf software acquired for personal use should not be subject to withholding tax.
