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 Deloitte NorwayIn Norway, the GAAR is non-statutory, and the rule has been largely developed by the Supreme Court.
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Sponsored by EY RomaniaIn January 2019, Romania's General Antifraud Directorate (DGAF) initiated a significant number of operative controls regarding transfer pricing (TP) documentation.
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Sponsored by Webber WentzelThe appointment of Edward Kieswetter as the new Commissioner for the South African Revenue Service (SARS) was announced at the end of March 2019.
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