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Dbriefs Bytes Central
12 August 2016
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
12 August 2016
1. BEPS (00:43)
1.1 CbC (00:55)
1.2 Other BEPS news (03:20)
- For a copy of the UK's All-Party Parliamentary Group on Responsible Tax report, click here and the American Bar Association Tax Section's letter to the IRS, click here
2. India: GST (04:26)
- For a copy of the Ministry of Finance Q&A guidance on the GST, click here
3. Australia (06:47)
3.1 Offshore hubs (07:07)
- For a copy of Singapore's statement regarding Indonesia's tax amnesty, click here
3.2 Arrangements involving offshore PEs (13:34)
- For a copy of the Taxpayer Alert regarding arrangements involving offshore PEs, click here
3.3 Other Taxpayer Alerts (17:27)
- For a copy of the other 2 Taxpayer Alerts regarding MAAL, click here and thin capitalisation, click here
- For information: David Watkins (Sydney)
4. Cases (17:50)
4.1 India: Steria (18:02)
4.2 India: Instrumentarium Corporation (24:20)
- For a copy of the Deloitte article on this case, click here
5. Asia Pacific (29:27)
- Australia, China, Indonesia, Korea, New Zealand, Sri Lanka
- For a copy of the Australian guidance regarding the high level design of the transfer pricing local file, click here and a copy of our slide deck summarising China's Bulletin 42, click here
6. Europe (32:11)
- Cyprus, Finland, Luxembourg, Slovenia, Turkey, UK
7. Africa (34:04)
- Mauritius, South Africa
- For a copy of our Tax Alert on South Africa's second Draft Notice in regard to record-keeping for transfer pricing purposes, click here
8. Americas (34:49)
- Canada, Panama, U.S.
9. Treaties (35:49)
- Czech Republic / Iran, Hong Kong / Romania, Hong Kong / Russia, Jersey / Rwanda, Macedonia / Saudi Arabia, Malaysia / Ukraine, Senegal / UK, Singapore / South Africa
BEPS: Likely impact on business models
Disregarded payment made by a hybrid (Part 2)
10 June 2016
Disregarded payment made by a hybrid (Part 1)
3 June 2016
Payments made to a reverse hybrid
15 April 2016
Cost contribution arrangements
8 April 2016
Downloadable digital products: source country taxation
19 February 2016
Internet advertising: source country taxation
12 February 2016
5 February 2016
15 January 2016
PE aspects of toll manufacturing
8 January 2016
Centralized purchasing or procurement, using an agency model
18 December 2015
Centralized purchasing or procurement, using a buy / sell model
4 December 2015
Calculation of the profits attributable to an Article 5(5) agency PE
27 November 2015
BEPS related material
UK's All-Party Parliamentary Group on Responsible Tax report
12 August 2016
American Bar Association Tax Section's letter to the IRS
12 August 2016
Discussion draft on Action 4
29 July 2016
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