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
6. Africa (59:35)
- Rwanda, Tanzania, Uganda
7. Treaties & Related Topics (1:00:54)
- Belarus / Spain, China / Sweden, Kyrgyzstan / UK
- To obtain a copy of the UN report, click here
BEPS: Likely impact on business models
Disregarded payment made by a hybrid (Part 2)
10 June 2016
Disregarded payment made by a hybrid (Part 1)
3 June 2016
Payments made to a reverse hybrid
15 April 2016
Cost contribution arrangements
8 April 2016
Downloadable digital products: source country taxation
19 February 2016
Internet advertising: source country taxation
12 February 2016
5 February 2016
15 January 2016
PE aspects of toll manufacturing
8 January 2016
Centralized purchasing or procurement, using an agency model
18 December 2015
Centralized purchasing or procurement, using a buy / sell model
4 December 2015
Calculation of the profits attributable to an Article 5(5) agency PE
27 November 2015
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