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Dbriefs Bytes Central

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 November 2017

10 November 2017

1. Transfer pricing: profit splits (00:44)

1.1 Introduction (00:52)

1.2 Unrelated parties (02:45)

1.3 Risk (06:16)

1.4 Profits to be split (08:49)

1.5 Profit-splitting factors (10:16)

1.6 Transactional profit / loss split method? (12:08)

  • To access the videos of this public consultation meeting, click here and here
  • To access Dbriefs Bytes: 14 July 2017, click here

 

2. Transfer pricing: attribution of profits to PE (12:50)

2.1 Introduction (12:58)

2.2 Examples (14:26)

2.3 Relationship between Article 7 and Article 9 (17:01)

  • To access the videos of this public consultation meeting, click here and here
  • To access Dbriefs Bytes: 7 July 2017, click here

 

3. Transfer pricing country profiles (27:14)

  • To access the OECD's transfer pricing country profiles, click here

 

4. US Tax Reform (28:35)

  • For a copy of our Tax Alert regarding amendments to the proposed 20% excise tax on certain outbound payment, click here, and the Senate Finance Committee's document, "Description of the Chairman's Mark of the Tax Cuts and Jobs Act", click here

 

5. Asia Pacific (31:37)

  • India, Singapore
  • For a copy of
    • India's final rules in regard to CbC reporting and the transfer pricing master file, click here
    • India's guidance in regard to the indirect share transfer provision, section 9(1)(i), click here
    • Singapore's updated guidance in regard to an important aspect of the GST zero-rating of international services, click here
    • Singapore's draft Carbon Pricing Bill, click here and here

 

6. Europe (34:31)

  • EU, France, Germany, Lithuania, Switzerland
  • For a copy of
    • Our Tax Alert regarding France's proposal for a major one-off corporate income tax increase, for large companies, click here
    • Germany's final guidance (in German) on situations in which outbound payments for software, cloud and database use would cause a withholding tax liability under domestic law, click here
    • Our Tax Alert on implementation of the cantonal tax reform project in the Swiss canton of Vaud, click here

 

7. Middle East & Central Asia (38:44)

  • GCC countries, UAE
  • For a copy of UAE's draft VAT regulations, click here

 

8. Treaties (39:43)

  • Belgium / Macedonia, Rwanda / UAE

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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

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3 November 2017
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