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Regulation for determination and payment of income tax relating to sale of securities by non-residents and foreign companies

The substantial impact of the Resolution is that it puts an end to a unclarity of the legal reform of 2013 that had levied transfer of shares with income tax, where it was not clear how would the income tax be withheld when both the acquiring party and the selling party were non-residents. Now, the Resolution regulates who will be the withholding agent in cases involving sales or transfers by non-residents or foreign companies.
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