Dbriefs Bytes Central

10 March 2017

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

Dbriefs Bytes: 10 March 2017

10 March 2017

1. BEPS: New Zealand (00:38)

1.1  Transfer pricing and PE avoidance (01:06)

1.2  Limitation of interest deductions (09:12)

1.3  Multilateral Convention (12:36)

  • To obtain a copy of
    • BEPS – Transfer pricing and permanent establishment avoidance, click here
    • BEPS – Strengthening our interest limitation rules, click here
    • New Zealand's implementation of the multilateral convention to implement tax treaty related measures to prevent BEPS, click here
    • Our Tax Alert on this topic, click here


2. BEPS: UN (14:24)

  • To obtain a copy of
    • UN practical portfolio - "Protecting the Tax Base of Developing Countries against Base Erosion: Income from Services", click here
    • UN practical portfolio - "Protecting the Tax Base of Developing Countries against Base-eroding Payments: Interest and Other Financing Expenses", click here


3. Asia Pacific (16:19)

  • Australia, Hong Kong, India
  • For a copy of
    • Consultation paper on proposed changes to Australia's inbound investment policies, click here
    • Australia's guidance on the requirement to include copies of international related party agreements in part B of the transfer pricing local file, click here
    • Hong Kong's paper calling for initiatives to enhance Hong Kong's position as an insurance hub (particularly reinsurance, marine, and captive), click here


4. Europe (19:54)

  • Cyprus, Denmark, ECJ, EU, Germany, Sweden, UK
  • For a copy of
    • Our Tax Alert regarding Cyprus's "back-to-back finance regime", click here
    • ECJ's decision regarding differential VAT rates permitted under VAT Directive for newspapers and periodicals if supplied in printed form, vs. if supplied in digital form, click here
    • ECJ's decision regarding the application of the original EU
      Parent / Subsidiary Directive to dividends paid by a Belgian limited partnership with a share capital, to two Netherlands FIIs, click here
    • ECJ's decision regarding merger tax relief legislation requiring additional conditions to be satisfied in the situation of a merger with a company in another Member State, vs. purely domestic merger, click here
    • European Parliament's report on EU / U.S. trade and investment relations: the effects on tax evasion, money laundering, and tax transparency, click here
    • Our Tax Alert regarding Germany's draft of amendments to the transfer pricing documentation decree, click here
    • Our 2 Tax Alerts regarding the UK's Budget 2017, click here and here


5. Africa (29:00)

  • Ghana, South Africa
  • For a copy of South Africa's 2 circulars on the export of IP, click here and here


6. Americas (30:39)

  • U.S.
  • For a copy of U.S.'s notice requesting public comments on the existing final regulations concerning the measurement of foreign currency transactions for qualified business units, click here


7. Treaties (33:51)

  • Belgium / India, Croatia / Kosovo, Jersey / Mauritius, Paraguay / Qatar

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2016 U.S. Model Treaty

Headquarters company
1 April 2016

Derivative benefits
18 March 2016

Special tax regimes
11 March 2016

Subsequent changes in law
4 March 2016

PEs in other States
26 February 2016

U.S. model treaty
19 February 2016


The last 8 Dbriefs Bytes videos (with full description) are available below. 

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- 3 March 2017
- 24 February 2017
- 17 February 2017
10 February 2017
- 27 January 2017
- 13 January 2017
- 6 January 2017
16 December 2016

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