Dbriefs Bytes Central

21 October 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

21 October 2016

1. U.S.: Section 385 debt / equity regulations (00:41)

1.1 Introduction (01:17)

1.2 Reg. 385-2: doc. rules: 4 requirements (05:18)

1.3 Reg. 385-2: doc. rules: master agreements, etc. (09:14)

1.4 Reg. 385-2: doc. rules: other points (10:47)

1.5 Reg. 385-3: introduction (15:51)

1.6 Reg. 385-3: "general rule" (16:35)

1.7 Reg. 385-3: "funding rule" (18:09)

1.8 Reg. 385-3: "anti-abuse rule" (20:05)

1.9 Reg. 385-3: exceptions (20:52)

1.10 Reg. 385-3: qualified short-term debt instruments (22:43)

1.11 Reg. 385-3: other points (24:14)

1.12 Other comments (24:56)

  • To obtain a copy of our Tax Alert, click here and the section 385 debt / equity regulations, click here


2. BEPS (26:53)

2.1 Public consultation meeting on transfer pricing matters (27:01)

2.2 Action 14: MAP peer review documents (30:40)

2.3 UN (31:18)

  • To obtain a copy of the MAP peer review documents, click here


3. Asia Pacific (31:38)

  • Australia, China, India, Vietnam
    • For a copy of Australia's draft legislation to amend the "aggregation" provision in debt / equity characterization rules, click here, here, and here, and our Tax Alert on this topic, click here. For a copy of Australia's draft ruling in regard to the participation exemption for foreign non-portfolio dividend, click here
    • For a copy of our Tax Alert on China's Bulletin 64, click here and our unofficial English translation of Bulletin 64, click here, for a copy of our slide deck on Frequently Asked Questions regarding China's Bulletin 42, click here and our Tax Alert regarding the relaxation of China's consumption tax on cosmetic products, click here
    • For a copy of India's final rules on the determination of "distributed income" in regard to share buy-backs, click here
    • For a copy our Tax Alert on Vietnam's proposal regarding transfer pricing documentation requirements, click here


4. Europe (36:09)

  • Belgium, Cyprus, EU, Iceland, Ireland, Italy, Poland, Spain
  • For a copy of our Tax Alert regarding Belgium's 2017 Budget, click here, and the European Commission’s reasons, click here, and our Tax Alert regarding the EU investigating Gibraltar’s tax ruling practices, click here. For a copy of a leaked version of the European Commission's CCCTB plan, click here


5. Americas (40:30)

  • Puerto Rico, U.S.
  • For a copy of Administrative Determination (AD) 16-11 (in Spanish), click here, and the IRS's announcement regarding U.S. taxpayers with maquiladora operations in Mexico, click here


6. Treaties (41:32)

  • Argentina / Chile, Austria / Liechtenstein, Belgium / Japan, Brunei / Kuwait, Cambodia / China, Georgia / Kyrgyzstan, Guernsey / Seychelles, Ireland / Pakistan, Korea / India, Korea / Tajikistan, Morocco / Rwanda, Portugal / Saudi Arabia

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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

BEPS related material

MAP peer review documents
21 October 2016

OECD's transfer pricing consultation meeting
7 October 2016


The last 8 Dbriefs Bytes videos (with full description) are available below. 

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- 7 October 2016
- 30 September 2016
- 16 September 2016
- 9 September 2016
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- 26 August 2016
- 19 August 2016
- 12 August 2016

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