Dbriefs Bytes Central

18 August 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: 18 August 2017

18 August 2017

1. 2017 OECD Model Treaty and Commentary: draft amendment (00:44)

  • To obtain a copy of the published comments on the draft amendments to the 2017 OECD Model Treaty and Commentary, click here

2. PPT Examples (03:09)

2.1 Introduction (03:17)

2.2 Example J (05:46)


3. Cases (20:34)

3.1 US: Starr International (20:47)

3.2 UK: DS Jersey (29:47)


4. Asia Pacific (39:29)

  • China, Indonesia, New Zealand
  • For a copy of
    • Indonesia's new regulation on CFCs (in Bahasa Indonesia), click here
    • New Zealand's BEPS consultation timetablet, click here
    • New Zealand's announcement regarding the review of its interpretation statement on tax avoidance, click here

5. Europe (45:27)

  • EU, Germany, Russia, Slovakia
  • For a copy of
    • European Commission's draft report on use of economic valuation techniques in transfer pricing, click here
    • Russia's guidelines to lower courts regarding various inbound investment topics (in Russian), click here
    • Slovakia's government announcement regarding the introduction of amending legislation to implement various parts of the EU's anti-tax avoidance directive, a patent box regime, and a virtual PE rule in regard to digital platforms (in Slovak)n, click here


6. Americas (47:58)

  • Brazil, Panama, US
  • For a copy of
    • Our Tax Alert on Brazil's new federal law to end "tax wars", click here
    • US's Revenue Procedure 2017-44, click here
    • US's Revenue Procedure 2017-45, click here 


7. Treaties (50:26)

  • MLI: Nigeria, Andorra / UAE, China / Romania, Egypt / Saudi Arabia


Breaking news

  • Chevron's Australian transfer pricing case on intra-group debt: Chevron has withdrawn its application for special leave to appeal to the High Court. Thus, the Full Federal Court decision will stand

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Principal Purposes Test (PPT) Examples

9 June 2017

2 June 2017

26 May 2017

19 May 2017

13 January 2017

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


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- 11 August 2017
28 July 2017
- 14 July 2017
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- 23 June 2017
- 16 June 2017
- 9 June 2017
- 2 June 2017

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