International Updates
Under the 60-day rule in Cyprus, individuals are considered tax residents of Cyprus and benefit from the island's tax regime.
On December 10 2018, Portugal published Notice 144/2018 in the Official Gazette, announcing the new income tax treaty with Montenegro.
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 AdvisorsOn April 18 2019, the Central Board of Direct Taxes (CBDT) issued a public consultation report, laying down its proposal for attribution of profits to a permanent establishment (PE) in India. The report is India's first attempt to codify rules on attribution of profits to a PE.
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Sponsored by KPMG Hong KongA number of offshore jurisdictions such as the Cayman Islands, the British Virgin Islands (BVI) and Bermuda have introduced economic substance laws.
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Sponsored by Yaron-Eldar Paller Schwartz & CoIsrael's Finance Ministry and tax authority announced in the last week of April that they intend to introduce a digital sales tax (DST) that may reap some $280 million for the treasury. The tax authorities will be working on a tax on the local sales turnover of foreign digital companies in Israel.
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