Dbriefs Bytes Central

23 June 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: 23 June 2017

23 June 2017

1. MLI: treaty impact analysis (00:39)

1.1  Introduction (00:47)

1.2  Intra-Americas treaties: analysis (03:18)

1.3  Intra-Americas treaties: summary (09:15)

1.4  Inter-Regional treaties: analysis (10:45)

1.5  Inter-Regional treaties: summary (26:55)

1.6  Comments in regard to Article 12 (28:10)

2. BEPS: Discussion drafts (31:13)

  • To obtain a copy of the OECD's discussion draft on the attribution of profits to PEs, click here, and discussion draft on profit splits, click here

3. Cases (33:33)

3.1  South Africa: Pienaar Brothers (Pty) Ltd (33:53)

3.2  Israel: Gteko (43:20)

4. Asia Pacific (47:50)

  • Australia, Cambodia, India, Singapore, Taiwan
  • For a copy of
    • Our Tax Alert regarding Australia's delay on the imposition of GST for low-value goods importation, click here
    • India's notification regarding secondary adjustments, click here
    • India's draft notification in regard to the "place of effective management" (POEM) test of corporate residence, click here
    • Our Tax Alert on the Indian case regarding outbound payments for the sharing of a "standard operating procedure", click here
    • India's release on 2 month relaxation of GST return filing rules, click here
    • India's new transfer pricing safe harbor regime, click here
    • Taiwan draft CFC rules (in Chinese), click here


5. Europe (57:05)

  • EU, Sweden, Switzerland
  • For a copy of European Commission's documents regarding proposed new transparency rules for intermediaries
    • Proposed directive on transparency rules for intermediaries, click here
    • Annex to proposed directive on transparency rules for intermediaries, click here
    • Press release, click here
    • Q&A, click here


6. Africa (59:35)

  • Rwanda, Tanzania, Uganda


7. Treaties & Related Topics (1:00:54)

7.1  Treaties

  • Belarus / Spain, China / Sweden, Kyrgyzstan / UK

7.2  UN

  • To obtain a copy of the UN report, click here

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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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- 16 June 2017
- 9 June 2017
- 2 June 2017
- 26 May 2017
- 19 May 2017
12 May 2017
- 5 May 2017
- 21 April 2017

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