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Dbriefs Bytes Central

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: 26 January 2018

26 January 2018

1. US tax reform: FDII & BEPS Action 5 (00:40)

1.1 Introduction (00:48)

1.2 BEPS Action 5: nexus approach for IP regimes (02:57)

1.3 BEPS Action 5: what is an "IP regime"? (07:12)

1.4 BEPS Action 5: non-IP regimes (11:53)

1.5 Bifurcation? (19:29)

1.6 Conclusions (21:58)

 

2. ICAP (23:44)

  • For a copy of the OECD's "International Compliance Assurance Programme Pilot Handbook", click here

 

3. Asia Pacific (24:53)

  • Australia, India
  • For a copy of
    • Australia's guidance on the attribution of equity to foreign branches of Australian banks, click here
    • Australia's expenses incurred in closing a petroleum project, click here  
    • Australia's capital gains withholding in regard to certain Australian real estate transactions undertaken by non-residents, click here
    • India's case regarding PE status under the India/Belgium treaty, click here
    • India's decision in the Vodafone case (transfer pricing), click here

 

4. Europe (29:46)

  • Cyprus, ECJ, EU, Finland, Greece, Poland, Romania, Sweden
  • For a copy of
    • Cyprus's guidance in regard to the claiming of VAT input tax credits by a holding company which exercises "active management" in regard to its subsidiaries (in Greek), click here
    • ECJ's decision in a VAT case concerning a single supply with two distinct elements, click here
    • European Commission’s status report on the implementation of the Union Customs Code, click here
    • Our Tax Alert regarding Finland's proposed amendments to the rules for interest deductions, click here
    • European Commission's report on VAT split payment systems, click here
    • Sweden's Administrative Court of Appeal decision in transfer pricing case (in Swedish), click here

 

5. Americas (36:16)

  • Peru, US
  • For a copy of
    • US's Notice 2018-13 regarding transition tax, click here
    • US Tax Court decision in section 956 case, click here

 

6. Treaties (38:53)

  • Azerbaijan/Denmark, Azerbaijan/Israel, Italy/Jamaica, UK/Uzbekistan
  • MLI signatories: Barbados, Côte d'Ivoire, Jamaica, Malaysia, Panama, Tunisia
  • MLI ratification: Poland

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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

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