Dbriefs Bytes Central

22 December 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: 22 December 2017

22 December 2017

1. US tax reform (00:39)

1.1 Corporate income tax rate, domestic dividends, and alternative minimum tax (AMT) (01:05)

1.2 Interest and net operating loss (NOL) deductions (02:38)

1.3 Full expensing of qualified property (05:58)

1.4 100% deduction for foreign dividends: "participation exemption" (06:58)

1.5 Deemed repatriation (09:08)

1.6 Intangible income: Global intangible low-taxed income (GILTI) (10:44)

1.7 Intangible income: Foreign-derived intangible income (FDII) (16:39)

1.8 Base erosion and anti-abuse tax (BEAT) (21:52)

1.9 Interest and royalties: outbound hybrid payments (26:13)

1.10 Alignment with BEPS Project (27:05)

1.11 Reading materials (29:27)

  • To obtain a copy of
    • Tax Cuts and Jobs Act, click here
    • Conference report, click here
      • Tax Alerts on this topic, click here
      • Slide deck, click here


2. OECD (29:54)

  • For a copy of
    • Second batch of stage 1 peer review reports regarding BEPS Action 14 minimum standards concerning MAP, and 4 "best practices" reports, click here
    • Online 2017 condensed version of OECD Model Treaty and Commentary, click here


3. Asia Pacific (31:50)

  • Australia, India, Japan, Malaysia
  • For a copy of
    • Australia's guidance in regard to the diverted profits tax
      • Draft Law Companion Guideline LCG 2017 / D7, click here
      • Law Administration Practice Statement PSLA 2017 / 2, click here
      • Tax Alert on this topic, click here
    • Final version of Australia's risk assessment approach for cross-border related party debt funding, click here, and Tax Alert on this topic, click here
    • India's GST Council statement regarding implementation of a nationwide e-way bill system for inter-state movement of goods, click here
    • Our Tax Alert regarding Japan's 2018 tax reform proposals, click here
    • Malaysia's explanatory note in regard to recent changes concerning withholding tax on services performed outside of Malaysia, click here


4. Europe (40:02)

  • Denmark, ECJ, EU, Luxembourg, UK
  • For a copy of
    • Denmark's court decision in regard to Art. 5 (in Danish), click here
    • European Court of Justice's decision in Avon Cosmetics case, click here
    • European Commission's announcement on its State Aid investigation in regard to two Netherlands private rulings given to a Dutch company within the IKEA group, click here
    • Luxembourg's guidance on certificate of tax residence for investment funds (in French), click here, and our Tax Alert on this topic, click here
    • UK Upper Tribunal decision in English Holdings (BVI) Ltd case, click here


5. Africa (47:03)

  • Ghana, South Africa
  • For a copy of South Africa's new draft carbon tax bill, click here and explanatory memorandum, click here


6. Treaties (48:11)

  • Croatia / Kosovo, France / Portugal, Qatar / Spain, Switzerland / UK, MLI : Jersey

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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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- 15 December 2017
- 24 November 2017
- 17 November 2017
- 10 November 2017
3 November 2017
- 27 October 2017
20 October 2017
- 13 October 2017

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