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 KPMG Hong KongA number of offshore jurisdictions such as the Cayman Islands, the British Virgin Islands (BVI) and Bermuda have introduced economic substance laws. -
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 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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