Dbriefs Bytes Central

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

15 July 2016

1. BEPS: China's new TP documentation rules (00:45)

1.1  Introduction (01:03)

1.2  CbC reporting (02:01)

1.3  Local file (04:42)

1.4  Master file (07:45)

1.5  Special issue file (08:34)

1.6  Other points (09:16)

  • For a copy of the Deloitte tax alert on Bulletin 42, click here and the unofficial English translation of Bulletin 42, click here
  • For information: Eunice Kuo (Shanghai)


2. BEPS Action 4: group ratio rule (11:19)

2.1  Introduction (11:44)

2.2  Calculation of net third party interest expense (14:49)

2.3  Definition of group-EBITDA (19:51)

2.4  Impact of losses (25:14)

2.5  Concluding comments (27:31)

  •  For a copy of the discussion draft: "Elements of the Design and Operation of the Group Ratio Rule", click here


3. BEPS: other news (28:25)


4. Asia Pacific (30:24)

  • India, New Zealand, Singapore, Taiwan
  • For a copy of the New Zealand consultation document on simplifying investment tax administration, click here, and for a copy of Singapore tax authorities' guidance on application of GAAR provision, click here


5. Europe (32:45)

  • European Court of Justice, EU, Ireland
  • For a copy of the ECJ's decision on withholding tax on interest derived by an Irish financial institution in Portugal, click here, for a copy of EC's press release on investigation against French and Belgian corporate tax exemptions to ports, click here, and for copy of the Irish tax authorities' guidance on obligations to exchange information on tax rulings, click here


6. Africa (34:31)

  • South Africa


7. Americas (35:07)

  • U.S.


8. Treaties (36:00)

  • Cyprus / Jersey, India / Kenya, Czech Republic / Kazakhstan

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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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- 8 July 2016
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