Events

Dbriefs Bytes Central

23 February 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: 23 February 2018

23 February 2018

1. US tax reform (00:39)

  • BEAT, FDII, transition tax, GILTI
  • For a copy of the Revenue Procedure 2018-17, click here

 

2. CV/BV structures: ATAD2 vs. GILTI (04:05)

2.1  Introduction (04:36)

2.2  ATAD2, Article 9 (before considering GILTI) (08:54)

2.3  ATAD2, Article 9 vs. GILTI (16:50)

2.4  ATAD2, Article 9a (before considering GILTI) (22:47)

2.5  ATAD2, Article 9a vs. GILTI (25:58)

2.6  Comments (28:46)

 

3. Other global developments: CRS, developing countries, and the UN (31:40)

  • For a copy of
    • OECD's consultation document in regard to preventing abuse of "residence by investment" schemes to circumvent the Common Reporting Standard, click here
    • Independent Commission for Reform of International Corporate Tax report, "A Roadmap to improve rules for taxing multinationals: A fairer future for global taxation", click here
    • UN Committee of Experts on International Cooperation in Tax Matters report on Fifteenth Session, click here  

 

4. Asia Pacific (33:54)

  • CPTPP, Australia, China, India, Singapore
  • For a copy of
    • Text of the Comprehensive and Progressive Agreement for Trans-Pacific Partnership, click here
    • Australia's draft legislation to tighten the existing MAAL rules, by including structures that use domestic partnerships or trusts
      • Exposure Draft legislation, click here
      • Explanatory Memorandum, click here
    • China's Bulletin 11 and its accompanying interpretation notice (in Chinese), click here and here
    • India's two AAR rulings concerning Mauritius resident companies and the capital gains exemption under Article 13 of the India/Mauritius treaty
      • AB Holdings, Mauritius-II, click here
      • AB Mauritius, click here
    • India's guidance on the changes to the taxation of long-term capital gains in the recent Budget, click here
    • Our Tax Alert on Singapore's 2018 Budget, click here

 

5. Europe (40:17)

  • Denmark, ECJ, Italy, Malta, Netherlands, Norway, Russia, UK
  • For a copy of
    • Denmark's National Tax Tribunal decision in transfer pricing case (in Danish) click here
    • ECJ's decisions in two cases regarding the compatibility of the Netherlands fiscal unity rules with EU's freedom of establishment, click here
    • Relevant documents regarding Italy's public consultation on proposed amendments to the transfer pricing regime (in Italian), click here
    • Malta's Notional Interest Deduction Rules, 2018, click here
    • Netherlands decree on tax consequences of the transfer, out of the Netherlands, of the effective management of a Netherlands incorporated company (in Dutch), click here
    • Netherlands government letter to the Dutch parliament, summarising results of recent review of country's APA and tax ruling practices, and foreshadowing some changes to procedures (in Dutch), click here
    • Norway's letter to the EFTA Surveillance Authority regarding State aid rules, click here
    • UK's guidance on the MAP process, click here
    • UK's consultation document regarding its public review of the corporate Intangible Fixed Assets regime, click here, and our Tax Alert on this topic, click here
    • UK tax tribunal decisions in two VAT cases
      • Hastings Insurance Services Ltd., click here
      • Fortyseven Park Street Ltd., click here

 

6. Africa (48:48)

  • Algeria, Ghana, Nigeria, South Africa
  • For a copy of
    • Algeria's guidance on the meaning of "services export", for the purposes of the exemption from corporate income tax (in French), click here
    • Our Tax Alert on South Africa's 2018 Budget, click here

 

7. Americas (51:16)

  • Brazil, US
  • For a copy of US government announcement regarding removal of 298 tax regulations, click here

 

8. Treaties (53:20)

  • Angola/UAE, Brazil/Korea, Brazil/South Africa, Ethiopia/Poland, Germany/Tunisia, India/Iran, Paraguay/Qatar, Saudi Arabia/Switzerland

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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

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