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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 Dhruva Advisors
    On 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.
  • Sponsored by EY Romania
    In January 2019, Romania's General Antifraud Directorate (DGAF) initiated a significant number of operative controls regarding transfer pricing (TP) documentation.
  • Sponsored by Russell McVeagh
    New Zealand's government has rejected the recommendation of its tax working group (TWG) that New Zealand introduce a capital gains tax (CGT). Announcing the government's decision, Prime Minister Jacinda Ardern acknowledged that while she personally saw merit in introducing a CGT, there was no mandate to proceed with introducing a CGT.