Dbriefs Bytes Central
14 July 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: 14 July 2017 - 200th episode
14 July 2017
1. 2017 OECD Model Treaty: draft amendments (00:38)
1.1 Introduction (00:46)
1.2 First group of draft amendments (02:02)
1.3 Second group of draft amendments (11:23)
- To obtain a copy of the draft amendments, click here
2. 2017 OECD Transfer Pricing Guidelines (12:13)
- To purchase from the OECD a copy of the 2017 OECD Transfer Pricing Guidelines, click here
3. BEPS: MLI Matching Database (13:42)
- To access the MLI Matching Database, click here
4. BEPS: Discussion draft on profit splits (18:17)
4.1 Introduction (18:25)
4.2 When is a transactional profit split method likely to be the most appropriate method to use? (19:21)
4.3 How should you determine the profits to be split? (27:28)
4.4 How should you split the profits? What are the profit splitting factors (32:27)
4.5 Examples (34:25)
4.6 Comments (36:47)
- To obtain a copy of the discussion draft, click here
5. Asia Pacific (38:20)
- India, Malaysia
- For a copy of
6. Europe (41:10)
- Finland, France, Iceland, Poland, Romania
- For a copy of
- Finland's consultation documents in regard to draft legislation on dividend withholding tax (in Finnish), click here and here
- Our Tax Alert on France's recent cases in regard to the claiming of foreign tax credits by French companies, click here
- France's 5 judgments regarding the PE status of GIL (in French), click here
7. Middle East & Central Asia (45:38)
- For a copy of UAE's updated VAT section, click here
8. Americas (46:49)
- Brazil, US
- For a copy of our Tax Alert on the Brazilian ruling regarding payments for procurement services, click here and US's notice on the existing regulations dealing with dual consolidated losses, click here
9. Treaties (47:55)
- MLI: Cameroon, MLI: Norway, Indonesia / Netherlands, Mexico / Spain, Moldova / UAE, Oman / Portugal
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
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