Dbriefs Bytes Central

3 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

3 June 2016

1. BEPS: news (00:38)

1.1   Multilateral instrument (00:51)

  • For a copy of the request document, click here

1.2   India's equalization levy starts operation (02:44)


2. UK: Secondary adjustments (03:34)

  • For a copy of the consultation document, click here
  • For information: John Henshall (London)


3. BEPS: Likely impact on business models: Disregarded payment made by a hybrid (08:54)

3.1  D/NI mismatch (09:36)

3.2  Example 1: hybrid entity (11:50)

3.3  Example 2: PE (15:12)

3.4  Dual inclusion income (19:42)

3.5  BEPS Report: domestic law recommendations (25:28)

3.6  Other points (26:29)


4. Asia Pacific (27:46)

  • Bangladesh, Hong Kong, India, Japan, New Zealand, Vietnam
  • For a copy of our Tax Alerts regarding Hong Kong's legislation on intragroup financing, click here and here, for a copy of Hong Kong's guidance regarding the profits tax exemption for offshore funds, click here, and a copy of our Tax Alert regarding New Zealand's GST on inbound digital supplies, click here


5. Europe (30:28)

  • EU, Finland, UK
  • For a copy of the draft report of the European Parliament's TAXE II committee, click here


6. Africa (31:26)

  • Malawi, Nigeria


7. Americas (32:20)

  • Brazil, Canada
  • For a copy of our Tax Alert regarding Brazil's consultation on "substantial economic activities", click here


8. Treaties (33:34)

  • Azerbaijan / San Marino, Cyprus / Latvia, Ethiopia / Korea, France / Singapore


9. Jeff VanderWolk (33:53)

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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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- 27 May 2016
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