Dbriefs Bytes Central

12 January 2018

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: 12 January 2018

12 January 2018

1. US tax reform (00:44)

1.1 What's in a name? (01:02)

1.2 Territorial system vs. full inclusion system (with foreign tax credits) (02:37)

1.3 GILTI: impact of foreign tax credits (06:51)

1.4 GILTI: impact of limited taxable income (09:45)

1.5 FDII (10:49)

1.6 BEAT (11:57)

1.7 Documents (15:14)

  • To obtain a copy of
    • Notice 2018-07, click here
    • Notice 2018-08, click here
    • Slide deck from US Dbriefs webcast, click here


2. Digital Taxation (16:17)

2.1 Taiwan (16:35)

2.2 Italy (21:26)

2.3 Slovakia (22:10)

  • For a copy of Taiwan's ruling regarding new rules on Taiwan-source income derived by non-resident suppliers (in Chinese), click here, and our Tax Alert on the topic, click here


3. Asia Pacific (23:10)

  • Australia, China, Hong Kong, Philippines, Thailand
  • For a copy of
    • Australia's government statement regarding deferral of the simplification of TOFA rules (taxation of financial arrangements), click here
    • China's Circular 88 (in Chinese), click here
    • China's Circular 84 (in Chinese), click here
    • Hong Kong's proposed legislation, click here and related government statements regarding the introduction a BEPS-compliant transfer pricing regime, click here
    • Philippines government announcement regarding the introduction of proposed legislation to significantly change the corporate income tax system, click here
    • Our Tax Alert on Thailand's proposed legislation to introduce a formal transfer pricing regime, click here


4. Europe (31:21)

  • Belgium, Denmark, ECJ, EU, France, Ireland, Italy, Netherlands, Russia, Serbia
  • For a copy of
    • Denmark's ruling in regard to the characterisation, for Danish tax purposes, of an Irish Common Contractual Fund (a CCF) (in Danish), click here
    • European Court of Justice's decision in Deister and Juhler case, click here
    • European Court of Justice's decision in Hamamatsu Photonics Deutschland case, click here
    • European Commission's announcement on its State Aid investigation in regard to two Netherlands private rulings given to a Dutch company within the IKEA group, click here
    • EU's three directives dealing with the reform of the VAT rules on e-commerce
      • 2017/2455, click here
      • 2017/2459, click here
      • 2017/2454, click here
    • European Commission's draft directive to make permanent the minimum 15% standard VAT rate, click here
    • Our Tax Alert regarding France's second amended finance bill for 2017 and finance bill for 2018, click here
    • Ireland's guidance in regard to the definition of trade, click here
    • Our Tax Alert regarding Italy's budget law for 2018, click here
    • Dutch Supreme court decision regarding fiscal unity between Dutch subsidiaries of Israeli parent company (in Dutch), click here


5. Africa (42:45)

  • South Africa
  • For a copy of South Africa's draft guidance in regard to section 23I, which denies deductions in regard to certain "tainted" intellectual property, click here


6. Middle East & Central Asia (43:46)

  • Gulf Cooperation Council countries, Uzbekistan


7. Americas (46:14)

  • Argentina, Brazil, Mexico
  • For a copy of 
    • Our Tax Alerts on the developments in Brazil with regard to the tax treatment of software transactions
      • Remittances made for right to distribute software deemed to be royalties, click here
      • State of Sao Paulo issues new rules on levy of state VAT on software, click here
    • Our Tax Alert regarding Mexico's Special Economic Zones, click here


8. Treaties (49:07)

  • Armenia / Germany, Cambodia / Singapore, Chad / Turkey, Cyprus / Saudi Arabia, Germany / Turkmenistan, Ghana / Netherlands, Hong Kong / Pakistan, Singapore / Sri Lanka

To avoid buffering when watching the video online, you can download the video by right clicking the link below and choose "Save target as" to save the video to your computer.

Download video

For access from China, you are recommended to click here to watch the video.

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. 

Click the links below to access. You can also choose to download the video by right clicking the "Download video" link on each individual page and choose "Save target as" to save the video to your computer. 

- 22 December 2017
- 15 December 2017
- 24 November 2017
- 17 November 2017
- 10 November 2017
3 November 2017
- 27 October 2017
20 October 2017

You can also find all the archived videos on iTunes / RSS / YouTube

How to view / subscribe Dbriefs Bytes

You can view or subscribe Dbriefs Bytes by the following channels:

Visit our website via

The latest video will be posted to our website weekly. Check with us every Friday.

Subscribe via iTunes / RSS feeds / YouTube channel

You can view Dbriefs Bytes on your mobile devices including iPhone, iPad, and Android. You can download the videos through iTunes or subscribe via RSS feeds or our YouTube channel. Simply click the following links to search the videos available online.

Subscribe via iTunes | Subscribe via RSS | Subscribe via YouTube

Updating your Dbriefs profile

If you want to join our subscription list, you can update your Dbriefs profile by checking the "Dbriefs Bytes" box under "My selection".


CPE/CPD information

Please note that CPE/CPD credit is NOT provided for watching Dbriefs Bytes. Please refer to our CPE/CPD information page for more details.

Contact us

For general enquiry and comments on Dbriefs Bytes, please send an email to

Disclaimer Note

Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee, and its network of member firms, each of which is a legally separate and independent entity. Please see for a detailed description of the legal structure of Deloitte Touche Tohmatsu Limited and its member firms.

Please note that the comments made in this presentation, to some extent, are based on material obtained from sources outside Deloitte.

This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms, or their related entities (collectively, the ″Deloitte network″) is, by means of this video, rendering professional advice or services.

No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this video.