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)
- 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
BEPS: Likely impact on business models
Disregarded payment made by a hybrid (Part 2)
10 June 2016
Disregarded payment made by a hybrid (Part 1)
3 June 2016
Payments made to a reverse hybrid
15 April 2016
Cost contribution arrangements
8 April 2016
Downloadable digital products: source country taxation
19 February 2016
Internet advertising: source country taxation
12 February 2016
5 February 2016
15 January 2016
PE aspects of toll manufacturing
8 January 2016
Centralized purchasing or procurement, using an agency model
18 December 2015
Centralized purchasing or procurement, using a buy / sell model
4 December 2015
Calculation of the profits attributable to an Article 5(5) agency PE
27 November 2015
BEPS related material
Schedule of Stage 1 peer reviews
4 November 2016
4 November 2016
MAP peer review documents
21 October 2016
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