Dbriefs Bytes Central

27 January 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: 27 January 2017

27 January 2017

1. TPP (00:40)


2. Brexit (03:26)

  • For a copy of Prime Minister's speech, click here, and the Supreme Court decision, click here


3. Transfer Pricing (07:44)

  • For a copy of the discussion draft, click here


4. Asia Pacific (08:58)

  • Australia, India, Malaysia
  • For a copy of
    • Australia's announcement regarding GST fraud scheme, click here
    • Our Tax Alert on Australia's draft legislation regarding the increase in level of penalties imposed on "significant global entities", click here
    • Australia's final guidelines regarding transfer pricing risks associated with offshore procurement, marketing, sales and distribution hubs, click here and our Tax Alert on the topic, click here
    • Our Tax Alert regarding India's GST start date deferral, click here, and India's final POEM guidelines, click here


5. Europe (18:46)

  • European Court of Justice, EU, Germany, Netherlands, Serbia
  • For a copy of
    • Mercedes Benz case (Italy VAT), click here
    • Our Tax Alert on Germany's decision to proceed with a bill to limit the deductibility of certain related party, cross-border royalty payments, click here
    • Netherlands: letter to the House of Representatives from Minister of Finance (in Dutch), click here


6. Americas (22:31)

  • U.S.
  • For a copy of
    • Final, temporary and proposed regulations in regard to transfers of appreciated property to partnerships with related foreign partners, click here and here
    • Final, temporary and proposed regulations in regard to inversion transactions, click here and here, and our Tax Alert on the topic, click here
    • Final, temporary and proposed regulations in regard to dividend equivalent payments from US sources, click here and here
    • Final regulations in regard to the qualifying income exception for publicly traded partnerships not to be treated as corporations for US tax purpose, click here
    • Final regulations in regard to certain transfers of property to regulated investment companies (RICs) and real estate investment trusts (REITs), click here
    • Corrections to the final and temporary section 385 regulations, click here and here
    • Revenue Procedure 2017-23, click here


7. Treaties (25:54)

  • Armenia / Belarus, Belarus / Hong Kong, Chile / Italy, Hungary / Iran, Hungary / Iraq, Hungary / Luxembourg, India / Kuwait, India / Slovenia, Japan / Latvia, Jersey / Seychelles, Paraguay / UAE, Portugal / Vietnam, Turkmenistan / UK, UAE / UK

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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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- 13 January 2017
- 6 January 2017
16 December 2016
- 2 December 2016
- 25 November 2016
- 18 November 2016
- 11 November 2016
- 4 November 2016

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