22 May 2015
Dbriefs Bytes brings you a weekly summary of the significant international tax developments impacting Asia Pacific. This video is broadcast every Friday afternoon. Stay tuned! Dbriefs Bytes is presented by Steve Towers, Asia Pacific Leader - International Tax
22 May 2015
1. BEPS: Action 7 (PE Status) (00:25)
1.1 Agency PE: Article 5(5)
- Option B
1.2 Agency PE: Article 5(6)
1.3 Exceptions in Article 5(4): preparatory or auxiliary character
- Option E
- "At the disposal" test under Article 5(1)
1.4 Exceptions in Article 5(4): anti-fragmentation
- Option J
1.5 Article 5(3): splitting-up of contracts
- Option L
- Option N
1.7 Attribution of profits
2. BEPS: other developments (31:00)
- Bob Stack (U.S. Treasury): Action 3
- Indian case: Baker Hughes
- Revised discussion draft on Action 6: scheduled today
3. China: Bulletin 16 (32:52)
- Possible conflict between Bulletin 16 and BEPS Action 8
- For a copy of our Tax Alert on Bulletin 16, click here
- For information: Vicky Wang (Shanghai) or Ye Hong (Shanghai)
4. In brief (36:52)
- For a copy of the five draft provisions for the U.S. model treaty, and the accompanying technical explanation,
– Click here for proposed Treaty Rule Addressing So-Called “Exempt Permanent Establishments”
– Click here for proposed Treasury Rules Addressing Payment by “Expatriated Entities”
– Click here for proposed Treaty Rules Addressing “Special Tax Regimes”
– Click here for proposed Limitation on Benefits Article
– Click here for proposed Article Addressing Subsequent Changes in Law
4.2 New Zealand Budget
- For a copy of the two documents (concerning VAT and APAs), click here and here
- For information: Gyung Ho Kim (Seoul) or Sunny Kim (Seoul)
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