Dbriefs Bytes Central
24 November 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: 24 November 2017
24 November 2017
1. Digital Taxation (00:39)
1.1 UK position paper (00:56)
- For a copy of the position paper, click here
1.2 Unilateral action (11:28)
2. Cases (12:25)
3. EU State Aid (22:31)
3.1 Introduction (22:40)
3.2 Group financing exemption under the UK's CFC rules (24:37)
- For a copy of the European Commission's letter regarding its decision to start a full investigation of the group financing exemption under the UK's CFC rules, click here
3.3 Germany's government report (36:53)
- For a copy of the government document on the European Commission's recent State Aid enforcement actions and their effects on Member State competence in tax policy (in German), click here
4. OECD (38:18)
- For a copy of the second round of peer reviews on the exchange of information on request, click here, and for the 2017 Implementation Report on the automatic exchange of information, click here
5. Asia Pacific (39:34)
- Australia, China, India, Singapore
- For a copy of
- Australia's draft legislation relating to hybrid mismatches
- China's Bulletin 40 (in Chinese), click here
- India's government order regarding the establishment of a task force to overhaul the country's direct tax system, click here
6. Europe (41:40)
- ECJ, France, UK
- For a copy of
- European Court of Justice's decision in Cussens's case: direct application, to Irish VAT, of the EU anti-avoidance principle concerning the abuse of rights, click here
- Our Tax Alert regarding France's second amended finance bill for 2017, click here
- Our Tax Alert regarding the UK's Autumn Budget 2017, click here
7. Americas (43:43)
- Chile, US
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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