Dbriefs Bytes Central

13 October 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 October 2017

13 October 2017

1. BEPS (00:49)

1.1 Digital (01:03)

1.2 International Compliance Assurance Program (ICAP) (04:10)

  • To obtain a copy of the ICAP information brochure, click here

1.3 Handbooks on CbC Reporting (05:20)

  • To obtain a copy of the Handbook on Effective Implementation, click here, a copy of the Handbook on Effective Tax Risk Assessment, click here

1.4  Public comments on PE profit attribution rules and profit splits (11:17)

  • To obtain a copy of
    • Comments on the attribution of profits to PE, click here
    • Comments on the revised guidance on profit splits: Part I, click here
    • Comments on the revised guidance on profit splits: Part II, click here


2. Denmark: PE ruling (12:14)

  • To obtain a copy of the ruling (in Danish), click here


3. Asia Pacific (20:22)

  • Hong Kong, India, Japan, Singapore
  • For a copy of
    • India's draft rules in regard to CbC reporting and the transfer pricing master file, click here
    • Japan's "Q&A" document on the mutual agreement procedure, click here


4. Europe (25:51)

  • EU, France, Ireland, Netherlands
  • For a copy of
    • EU
      • European Commission's various documents regarding comprehensive VAT reform
        • Study on the VAT Gap for 2015, click here
        • Press release, click here
        • FAQ on VAT, click here
        • Plan for VAT One-Stop Shop
          • Proposal, click here
          • Announcement, click here
          • Q&A, click here
      • Tax Dispute Resolution Directive, click here
    • France
      • Tax Alert on the French Constitutional Court ruling finding the 3% surtax on dividends unconstitutional, click here


5. Africa (33:40)

  • African Tax Administration Forum, Zambia
  • For a copy of ATAF report: "Toolkit for Transfer Pricing Risk Assessment in the African Mining Industry", click here


6. Americas (38:26)

  • Brazil, Mexico, Uruguay, US, Venezuela
  • For a copy of
    • Our Tax Alert regarding the Senate Finance Committee hearing on international tax aspects of US tax reform, click here
    • US Treasury's report in regard to reducing tax regulatory burdens, click here and our Tax Alert on this topic, click here
    • Our Tax Alert regarding Notice 2017-57, click here
    • US District Court for Western District of Texas decision in Chamber of Commerce case, click here


7. Treaties (46:19)

  • Armenia / Belarus, Belarus / Ecuador, Botswana / Malta, Costa Rica / UAE,  Denmark / Japan, India / Kenya, Iraq / UAE, Morocco / Zambia, Turkey / Ukraine, Ukraine / UK

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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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- 29 September 2017
- 22 September 2017
- 15 September 2017
- 8 September 2017
- 25 August 2017
- 18 August 2017
- 11 August 2017
28 July 2017

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