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

To avoid buffering when watching the video online, you can download the video by right clicking the link below and choose "Save target as" to save the video to your computer.

Download video

For access from China, you are recommended to click here to watch the video.

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. 

Click the links below to access. You can also choose to download the video by right clicking the "Download video" link on each individual page and choose "Save target as" to save the video to your computer. 

- 9 February 2018
- 2 February 2018
26 January 2018
- 19 January 2018
- 12 January 2018
- 22 December 2017
- 15 December 2017
- 24 November 2017

You can also find all the archived videos on iTunes / RSS / YouTube

How to view / subscribe Dbriefs Bytes

You can view or subscribe Dbriefs Bytes by the following channels:

Visit our website via

The latest video will be posted to our website weekly. Check with us every Friday.

Subscribe via iTunes / RSS feeds / YouTube channel

You can view Dbriefs Bytes on your mobile devices including iPhone, iPad, and Android. You can download the videos through iTunes or subscribe via RSS feeds or our YouTube channel. Simply click the following links to search the videos available online.

Subscribe via iTunes | Subscribe via RSS | Subscribe via YouTube

Updating your Dbriefs profile

If you want to join our subscription list, you can update your Dbriefs profile by checking the "Dbriefs Bytes" box under "My selection".


CPE/CPD information

Please note that CPE/CPD credit is NOT provided for watching Dbriefs Bytes. Please refer to our CPE/CPD information page for more details.

Contact us

For general enquiry and comments on Dbriefs Bytes, please send an email to

Disclaimer Note

Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited, a UK private company limited by guarantee, and its network of member firms, each of which is a legally separate and independent entity. Please see for a detailed description of the legal structure of Deloitte Touche Tohmatsu Limited and its member firms.

Please note that the comments made in this presentation, to some extent, are based on material obtained from sources outside Deloitte.

This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms, or their related entities (collectively, the ″Deloitte network″) is, by means of this video, rendering professional advice or services.

No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this video.