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

Our current Dbriefs Bytes is 6 January, and our next Dbriefs Bytes will be broadcast on 13 January

Dbriefs Bytes: 6 January 2017

6 January 2017

1. BEPS (00:44)

  • 1.1 Action 4 (00:57)
  • To obtain a copy of the new version of the Action 4 Report, click here
  • 1.2 CbC (02:34)
  • 1.3 MLI / MLC (04:05)
  • To obtain a copy of Australia's consultation paper on the Multilateral Convention, click here
  • 1.4 Exchange of rulings (05:25)


2. Protocol to India / Singapore treaty (06:05)


3. Cases (09:40)

  • 3.1  Canada: 2 "rectification" cases (09:58)
  • To obtain a copy of the JC Group decision, click here, and the Fairmont Hotels decision, click here
  • 3.2 ECJ: Spanish goodwill cases – State Aid (13:01)
  • To obtain a copy of this decision, click here, and our Tax Alert on the case, click here
  • 3.3 ECJ: Aer Lingus and Ryanair – State Aid (16:19)
  • To obtain a copy of this decision, click here
  • 3.4 ECJ: Masco Denmark and Damixa case – Freedom of Establishment (19:28)
  • To obtain a copy of this decision, click here


4. Asia Pacific (22:39)

  • Australia, China, Hong Kong, India, Singapore, Taiwan
  • For a copy of
    • Australia's draft ruling in regard to "override royalty payments", click here
    • Australia's draft ruling in regard to the application of the new GST rules on inbound services and digital supplies, click here
    • Tax Alert on Circular 140 and Bulletin 86 regarding changes to China's VAT rule draft explanatory notes for Finance Bill 2017, click here
    • China's APA report 2015, click here
    • Hong Kong's updated guidance in regard to the tax treatment of court-free amalgamations, click here, and our Tax Alert on this topic, click here
    • India's Q&A document on the operation of the indirect share transfer provision, section 9(1)(i), click here
    • India's Q&A document in regard to the Direct Tax Dispute Resolution Scheme, click here
    • Singapore's guidance on the application of GST to the logistics service industry, click here


5. Europe (30:48)

  • EU, France, Germany, Italy, Russia
  • For a copy of
    • European Commission's 3 VAT consultation questionnaires, click herehere, and, here
    • Proposed amendment to the EU VAT Directive, click here
    • European Commission's 2 transfer pricing studies, click here, and here
    • European Commission’s full, but redacted, decision in regard to the Apple State Aid case, click here
    • Our Tax Alert on France's Amending Finance Bill 2016 and Finance Bill 2017, click here
    • Our Tax Alert on Germany's draft provision in regard to the deductibility of related party, cross-border royalty payments, click here
    • Our Tax Alert on Italy's Budget law for 2017, click here
    • Our Tax Alert on Russia's new VAT rules on B2C inbound digital services, click here


6. Africa (40:37)

  • South Africa, Zimbabwe
  • For a copy of South Africa's 2016 Taxation Laws Amendment Bill, click here, and Explanatory Memorandum, click here


7. Middle East & Central Asia (42:33)

  • Israel


8. Americas (43:40)

  • Argentina, Brazil, U.S.
  • For a copy of
    • Our Tax Alert in regard to Brazil's guidance on the "grey list" status of Austrian holding companies, click here
    • U.S. final regulations under section 367(a) and (d), click here, and our Tax Alert on the topic, click here
    • U.S. final regulations in regard to passive foreign investment companies (PFICs), click here
    • U.S. temporary and proposed regulations under section 355(e), click here and here
    • U.S. corrections in regard to CFC regulations, click here and here


9. Treaties (49:08)

  • Albania / Switzerland, Austria / Liechtenstein, Azerbaijan / Sweden, Brunei / Luxembourg, Canada / Israel, Canada / Taiwan, China (Mainland) / Macau, China / Malaysia, China / Zimbabwe, Chile / Czech Republic, Chile / Japan, Cyprus / India, Cyprus / Russia, Guernsey / UK, India / Singapore, India / Tajikistan, Kazakhstan / Serbia, Liechtenstein / Georgia, Luxembourg / Serbia, Luxembourg / Uruguay, Malta / Vietnam, Norway / Switzerland, Poland / Taiwan, Qatar / Turkey, Romania / UAE, Saudi Arabia / Venezuela, Singapore / South Africa, South Africa / UAE

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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. 

Click the links below to access. You can also choose to download the video by right clicking the "Download video" link on each individual page and choose "Save target as" to save the video to your computer. 

- 16 December 2016
- 2 December 2016
- 25 November 2016
- 18 November 2016
- 11 November 2016
- 4 November 2016
28 October 2016
- 21 October 2016

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