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 MDDPFrom July 1 2019, payments from Poland abroad that are subject to a withholding tax (WHT) regime and exceeding PLN 2 million ($520,000) will be subject to a standard 19%/20% WHT rate. -
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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