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

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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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- 12 January 2018
- 22 December 2017
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- 24 November 2017
- 17 November 2017
- 10 November 2017
3 November 2017
- 27 October 2017

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