Dbriefs Bytes Central
19 January 2018
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: 19 January 2018
19 January 2018
1. US tax reform: global impact (00:44)
1.1 Impact on "hub jurisdictions" (01:05)
1.2 Impact on high tax countries (10:46)
1.3 Impact on foreign country CFC rules (13:35)
1.4 Impact of BEAT (15:05)
2. 2017 Edition of OECD Model Treaty and Commentary: Art. 5(2) & (3) (16:50)
2.1 Introduction (16:58)
2.2 Art. 5(2): status of Art. 5(2) and relationship with Art. 5(1) (17:40)
2.3 Art. 5(2): Observations/Positions on the Commentary (19:21)
2.4 Art. 5(3): fragmentation (20:01)
2.5 Art. 5(3): subcontractors and relationship with Art. 5 (1) (21:47)
2.6 Art. 5(3): measuring time (24:58)
2.7 Art. 5(3): partnerships (27:37)
2.8 Art. 5(3): Observations/Positions on the Commentary (29:48)
3. Asia Pacific (30:52)
- China, India, Korea, Malaysia, New Zealand
- For a copy of
- China's Bulletin 1 of 2018 in regard to consumption tax on various refined oil products, click here, and the accompanying interpretation notice (in Chinese), click here
- China's Bulletin 3 of 2018 regarding further guidance on the deferral of dividend withholding tax on certain dividends reinvested in China (in Chinese), click here
- India's government announcement regarding amendments to its policy concerning foreign direct investments (FDI), click here
- Korea's announcement regarding revisions to 17 tax enforcement decrees, click here
- Malaysia's MAP guidelines, click here
- New Zealand's High Court decision in Chatfield case, click here
4. Europe (40:03)
- Belarus, EGC, EU, Switzerland, UK
- For a copy of
- EGC's decision in EDF State Aid case (in French), click here, and EGC's summary (in English), click here
- European Commission's announcement regarding its launch of an in-depth State Aid investigation into a special tax regime in Poland for shipyards, click here
- European Commission's proposal which would permit Member States greater flexibility in regard to the setting and application of their lower VAT rates, click here
- European Commission's proposal in regard to the special VAT scheme for small and medium-sized enterprises (SMEs), click here
- Switzerland's Circular 13 on the tax treatment of securities lending, borrowing and repo transactions (in German)
- Our Tax Alert regarding Switzerland's update on the timeline for the implementation of Corporate Tax Reform 17, click here
- UK's guidance in regard to Serial Tax Avoidance Regime, click here, and the disclosure of tax avoidance schemes (DOTAS), click here
5. Americas (45:46)
- Ecuador, US
- For a copy of US Notice 2018-05 in regard to withholding tax on substitute dividend payments, click here
6. Treaties (47:36)
- Cambodia / Thailand, Czech Republic / Korea, Iceland / Japan, Ireland / Kazakhstan, Qatar / Spain
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
The last 8 Dbriefs Bytes videos (with full description) are available below.
Click the links below to access. You can also choose to download the video by right clicking the "Download video" link on each individual page and choose "Save target as" to save the video to your computer.
How to view / subscribe Dbriefs Bytes
You can view or subscribe Dbriefs Bytes by the following channels:
Visit our website via www.deloitte.com/ap/dbriefs/bytes
The latest video will be posted to our website weekly. Check with us every Friday.
Subscribe via iTunes / RSS feeds / YouTube channel
You can view Dbriefs Bytes on your mobile devices including iPhone, iPad, and Android. You can download the videos through iTunes or subscribe via RSS feeds or our YouTube channel. Simply click the following links to search the videos available online.
Updating your Dbriefs profile
If you want to join our subscription list, you can update your Dbriefs profile by checking the "Dbriefs Bytes" box under "My selection".
Please note that CPE/CPD credit is NOT provided for watching Dbriefs Bytes. Please refer to our CPE/CPD information page for more details.
Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee, and its network of member firms, each of which is a legally separate and independent entity. Please see www.deloitte.com/about for a detailed description of the legal structure of Deloitte Touche Tohmatsu Limited and its member firms.
Please note that the comments made in this presentation, to some extent, are based on material obtained from sources outside Deloitte.
This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms, or their related entities (collectively, the ″Deloitte network″) is, by means of this video, rendering professional advice or services.
No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this video.