India: CBDT issues draft guidelines for determination of a company’s place of effective management
India's Central Board of Direct Taxes (CBDT) has issued draft guiding principles for determining if a company is a resident in India or has its place of effective management in India. The Finance Act 2015 amended the provisions of section 6(3) of
See MoreCyprus – Company incorporated, but not tax resident of Cyprus
Circular 2014/3 of March 2014 gives guidance in respect of the tax return requirements in the situation where a company is incorporated in Cyprus but is not tax resident in the country. According to the Circular companies in this position must be
See MoreNew Zealand: New rules for determining tax residence
In New Zealand the Inland Revenue Department has issued an “interpretation statement” on tax residence. This is an update to previous guidance from 1989. The new statement takes effect from 1 April 2014 and includes residence criteria for
See MoreItalian Supreme Court rules on tax residence concept
The Italian Supreme Court gave its decision on 17 January 2014 in case No. 1811 concerning the issue of whether the Maltese company should be considered resident in Italy for tax purposes. The case particularly concerned the provision that a company
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