Dbriefs Bytes

10 April 2015

Dbriefs Bytes brings you a weekly summary of the significant international tax developments impacting Asia Pacific. This video is broadcast every Friday afternoon. Stay tuned!  Dbriefs Bytes is presented by Steve Towers, Asia Pacific Leader - International Tax

10 April 2015

1. BEPS Action 12: Mandatory Disclosure Rules (00:25)

  • For a copy of the Action 12 discussion draft, visit click here

2. BEPS Action 3: Strengthening CFC Rules (01:09)

  • Interaction with EU law
  • Definition of CFCs: non-corporate entities
  • Hybrid mismatch arrangements: U.S. check the box rules
  • Low-tax threshold
  • Tax rate to apply to CFC income
  • "Primary rule" / "secondary rule" framework
  • For a copy of the Action 3 discussion draft, visit click here

3. BEPS: other developments (21:35)

3.1 BEPS Action 5: harmful tax practices

3.2 EU and OECD: in love

3.3 BEPS Actions 8-10: transfer pricing

3.4 BEPS Action 14: dispute resolution

3.5 UK

  • For a copy of the two reports from the Public Accounts Committee, click here and here, the press release from the UK tax authorities in regard to the E6 project, click here and the update guidance on the diverted profits tax, click here
  • For information: Bill Dodwell (London)

3.6 Australia

  • To follow the proceedings of the Senate inquiry, click here
  • For information: David Watkins (Sydney)

3.7 China

4. India (33:59)

4.1 APA rollbacks

4.2 Section 9(1)(i): dividends

  • For a copy of the statement issued by the Central Board of Direct Taxes, click here
  • For information: N.C. Hegde (Mumbai)

4.3 Cairn

5. In brief (37:27)

5.1 Treaties

  • China / Hong Kong protocol signed
  • China / Indonesia protocol signed
  • Korea / Nigeria treaty enters into force
  • India / Czechoslovakia treaty continues to apply to India and Slovakia

5.2 Australia

  • For a copy of the Treasury's discussion paper on possible tax reforms, click here, and for a copy of the Board of Taxation's report on debt and equity tax rules, click here
  • For information: David Watkins (Sydney)

5.3 Malaysia

  • For a copy of the guidelines on the new incentives, click here
  • For information: Tan Hooi Beng (Kuala Lumpur)

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