Dbriefs Bytes Central

18 November 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: 18 November 2016

18 November 2016

1. BEPS (00:38)

1.1 CbC (00:51)

1.2 France: diverted profits tax / MAAL? (02:52)

1.3 EU: Action 12 (03:35)

  • To obtain a copy of EU's consultation document on possible EU action on advisors and intermediaries who facilitate tax evasion and tax avoidance, click here

1.4 Malaysia: inbound digital services (04:59)

1.5 India: inbound digital services (08:59)

1.6 Other BEPS news (11:06)

  • To obtain a copy of our Tax Alert regarding India levying a 15% service tax on certain inbound digital services, click here and, for a copy of the OECD's discussion paper, "Distinguishing between 'normal' and 'excess' returns for tax policy" click here


2. Asia Pacific (12:07)

  • Australia, China, Maldives, Sri Lanka


3. Europe (16:42)

  • Austria, Denmark, EU, France, Russia, Sweden, UK
  • To obtain a copy of our Austria's consultation document on draft amendments in regard to the Reorganization Tax Act (in German) (240 pages), click here. For a copy of Denmark's ruling on the tax treatment of a transfer of place of effective management (POEM) of a Danish company, from Denmark to Spain (in Danish) , click here. For a copy of the France's updated guidance on the "most favoured nation" (MFN) provisions (in French), click here, and UK's updated guidance in regard to their APA program, click here


4. Americas (22:56)

  • Brazil
  • For a copy of Normative Ruling NR 1,669 / 16 providing guidance on the MAP procedure under Brazil's treaties, click here


5. Treaties (23:36)

  • Cyprus / Latvia, Ecuador / Russia, Estonia / Vietnam, Finland / Sri Lanka, Laos / Singapore

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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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- 11 November 2016
- 4 November 2016
28 October 2016
- 21 October 2016
- 7 October 2016
- 30 September 2016
- 16 September 2016
- 9 September 2016

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