Dbriefs Bytes Central

16 December 2016

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: 16 December 2016

16 December 2016

1. BEPS (00:35)

1.1 CbC (00:48)

  • To obtain a copy of the updated implementation guidance on CbC reporting, click here

1.2 EU: hybrid mismatches (04:14)

1.3 New Zealand: DPT & MAAL (06:43)

  • To obtain a copy of the New Zealand Cabinet paper, click here


2. Cases (07:45)

2.1 Finland: Mobile game developer (07:58)

2.2 India: Formula One World Championship (17:46)


3. Asia Pacific (28:49)

  • Australia, Japan, Taiwan
  • For a copy of Australia's discussion paper on the application of the new GST rules concerning "electronic distribution platforms", click here. For a copy of Australia's Corporate Tax Transparency Report for 2014-15, click here. For a copy of Japan's Outline of the 2017 Tax Reform Proposals (in Japanese), click here


4. Europe (33:03)

  • Spain, UK
  • For a copy of our Tax Alert on Spain's restrictive limitations imposed on carry forward of tax losses, click here. For a copy of the UK's draft provisions for Finance Bill 2017, click here, draft explanatory notes for Finance Bill 2017, click here, draft guidance on hybrid mismatches, click here, consultation on the reform of the substantial shareholding exemption, click here, consultation on the scope of VAT grouping, click here


5. Americas (35:28)

  • Brazil, Peru, U.S.
  • For a copy of
    • Our Tax Alert regarding Brazil's Normative Ruling 1,674/2016, click here
    • Temporary and proposed regulations addressing covered asset acquisitions under section 901(m), and our Tax Alert on the topic, click here, here, and here
    • Notice 2016-73 and our Tax Alert on the topic, click here, and here
    • Our Tax Alert regarding the final, temporary and proposed regulations concerning "qualified business units", subject to section 987, click here
    • Notice 2016-76, click here
    • Final regulations concerning the issue price of tax-exempt bonds, click here
    • Final regulations concerning reporting requirements for foreign-owned domestic disregarded entities, click here
    • Draft Form 8975 and Schedule A, click here, and here
    • GOP Tax Plan, click here

6. Treaties (43:20)

  • Australia / Germany, Azerbaijan / Israel, Bosnia & Herzegovina / Romania, Canada / Madagascar, China / Pakistan, Ecuador / Italy, Georgia / Korea, Hong Kong / Romania, Korea / Turkmenistan, Luxembourg / Tunisia, Romania / UAE

7. 12 Days of Christmas (43:43)

  • To obtain a copy of "A Taxing Review of the Twelve Days of Christmas", click here

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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

BEPS related material

New Zealand Cabinet paper
16 December 2016

Implementation guidance on CbC reporting
16 December 2016

OECD Tax Talks Webcast
2 December 2016

Tax Alert on Australia: diverted profits tax
2 December 2016

Draft explanatory memorandum
2 December 2016

Exposure draft legislation
2 December 2016

Tax Alert on the MLC
2 December 2016

Accompanying Explanatory Statement
25 November 2016

25 November 2016


The last 8 Dbriefs Bytes videos (with full description) are available below. 

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- 2 December 2016
- 25 November 2016
- 18 November 2016
- 11 November 2016
- 4 November 2016
28 October 2016
- 21 October 2016
- 7 October 2016

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