Dbriefs Bytes Central

26 August 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

26 August 2016

1. BEPS: Branch mismatch structures (00:43)

1.1  D/NI: Disregarded branch structure (02:25)

1.2  D/NI: Diverted branch payment (05:02)

1.3  D/NI: Deemed branch payments (09:13)

1.4  DD branch payments (14:25)

1.5  Indirect D/NI: Imported branch mismatches (19:59)

1.6  Other comments (21:34)

  • For a copy of the discussion draft, click here


2. BEPS: other news (22:29)

  • For a copy of comments received regarding the conforming amendments to chapter IX of the OECD’s Transfer Pricing Guidelines, click here, for a copy of comments received on the discussion draft on the design and operation of the group ratio rule under BEPS Action 4, click here, for a copy of Brazil’s consultation document (in Portuguese) and our Tax Alert regarding rules for the conduct of mutual agreement procedure, click here and here


3. EU State Aid (24:18)

  • For a copy of the U.S. Treasury’s white paper, click here


4. Asia Pacific (29:58)

  • Australia, Hong Kong, Philippines
  • For a copy of Australia’s voluntary Tax Transparency Code, click here, for a copy of Philippines’s Revenue Memorandum Order regarding treaty benefits, click here


5. Europe (33:18)

  • France


6. Americas (33:41)

  • Colombia, Puerto Rico, U.S.
  • For a copy of our Tax Alert regarding the Colombian ruling on the tax treatment of transportation services provided by nonresidents,
    click here


7. Treaties (35:38)

  • Ethiopia / Singapore, Kazakhstan / Saudi Arabia

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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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- 19 August 2016
- 12 August 2016
29 July 2016
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