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
    • Malaysia's guidance on the application of withholding tax on outbound service payments
      • Practice Note 1/2017, click here
      • Practice Note 2/2017, click here
    • Malaysia's changes to its transfer pricing guidelines, click here


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)

  • UAE
  • 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

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. 

- 7 July 2017
- 23 June 2017
- 16 June 2017
- 9 June 2017
- 2 June 2017
- 26 May 2017
- 19 May 2017
12 May 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.