Dbriefs Bytes Central
24 June 2016
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
24 June 2016
1. BEPS: EU’s ATAD (00:45)
1.1 Interest deductions (01:54)
1.2 CFC rules (07:09)
1.3 Hybrid mismatches (09:50)
1.4 Exit taxation (12:52)
1.5 GAAR (14:51)
1.6 Timing (16:32)
2. BEPS: other news (17:11)
2.1 OECD webcast (17:26)
2.2 Actions 8-10: OECD’s Transfer Pricing Guidelines (19:03)
2.3 Inclusive framework (20:20)
3. India: equalisation levy (21:43)
- For information: Sunil Shah (Mumbai)
4. Luxembourg company with a U.S. branch (29:48)
5. Asia Pacific (31:22)
- China / Hong Kong, India
- For a copy of our Tax Alert on the new administrative arrangements for certificates of residence (COR) under the China / Hong Kong DTA, click here
6. Europe (32:56)
- EU, Netherlands, Poland, Russia, Switzerland
- For a copy of our Tax Alert on the Swiss parliament’s approval of Corporate Tax Reform III, click here
7. Africa (34:50)
- East Africa (Kenya, Rwanda, Tanzania, and Uganda)
- For a copy of the Tax Justice Network / ActionAid report, click here
8. Middle East and Central Asia (36:16)
- Gulf Cooperation Council (Bahrain, Kuwait, Oman, Qatar, Saudi Arabia, and UAE)
9. Americas (36:48)
- Brazil, U.S.
10. Treaties (38:30)
- Curaçao / Netherlands, Japan / Taiwan, Mali / Morocco, Turkmenistan / UK
BEPS: Likely impact on business models
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
BEPS related material
UK consultation document
20 May 2016
Discussion paper on Action 12
6 May 2016
Corporate tax avoidance
6 May 2016
Deloitte Tax alert
6 May 2016
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