Dbriefs Bytes Central

13 January 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: 13 January 2017

13 January 2017

1. BEPS Action 6: Non-CIV Funds (00:38)

1.1 Introduction (00:46)

1.2 Regional investment platform example (03:56)

1.3 Securitisation company example (10:38)

1.4 Immovable property non-CIV fund example (16:49)

1.5 Examples and the text of the PPT (21:37)

1.6 Other issues (24:08)

  • To obtain a copy of the discussion draft, click here


2. Asia Pacific (26:43)

  • Hong Kong, India, Singapore
  • For a copy of
    • Hong Kong's Financial Services Development Council paper, click here
    • Singapore's updated guidance on Tax treatment of REITs (real estate investment trusts), click here, Discretionary tax exemption (under section 13(12)) for certain foreign sourced income, click here, and Transfer pricing, click here


3. Europe (29:34)

  • Denmark, Germany, EU, Netherlands, Georgia, Switzerland
  • For a copy of European Commission's decision in the State aid probe of Luxembourg tax rulings granted to GDF Suez (Engie), click here, and for a copy of our Tax Alert on Germany's legislation regarding additional relief from change-in-ownership rules, click here


4. Americas (36:36)

  • Brazil, Colombia, Peru


5. Treaties (39:20)

  • Albania / Iceland, Canada / UK, India / Kazakhstan, Isle of Man / UK, Jersey / UK, South Africa / Zimbabwe

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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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- 6 January 2017
16 December 2016
- 2 December 2016
- 25 November 2016
- 18 November 2016
- 11 November 2016
- 4 November 2016
28 October 2016

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