Dbriefs Bytes Central

19 May 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: 19 May 2017

19 May 2017

1. PPT (00:38)

1.1  Article 7(1), Multilateral Convention (01:41)

1.2  Article 7(4), Multilateral Convention (08:58)

1.3  Examples in proposed Commentary (12:40)

1.4  Example A (14:59)

1.5  Example B (17:43)

2. Asia Pacific (20:45)

  • Australia, India, Singapore
  • For a copy of Australia's draft guidance on the ATO's transfer pricing risk assessment framework concerning cross-border related party financing arrangements, click here, and our Tax Alert on this topic, click here

3. Europe (24:26)

  • Belarus, ECJ, Germany, Hungary, Netherlands, Norway
  • For a copy of
    • ECJ's decisions on the Belgian 5.15% "fairness tax", click here
    • The French 3% "additional contribution to corporation tax", click here
    • Our Tax Alert on the French case, click here

4. Africa (34:25)

  • Nigeria


5. Americas (35:15)

  • US
  • For a copy of US's notice requesting public comments on the existing regulations which deal with overall foreign losses (OFLs) and overall domestic losses (ODLs), in regard to the foreign tax credit limitation, click here

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Principal Purpose Test (PPT)

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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12 May 2017
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