Dbriefs Bytes Central

8 July 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

8 July 2016

1. BEPS Action 7: PEs (00:38)

1.1  Introduction (01:28)

1.2  Example 1 (07:29)

1.3  Example 2 (10:03)

1.4  Example 3 (14:25)

1.5  Example 4 (16:22)

1.6  Example 5 (19:10)

1.7  Final comments (21:51)

  • For a copy of the discussion draft on how to calculate the profits attributable to a PE, click here


2. BEPS Actions 8 – 10: profit splits (22:37)

2.1  Introduction (22:45)

2.2  Profit split based on anticipated profits (25:01)

2.3  Profit split based on actual profits (26:37)

2.4 Guidance for application (31:08)

  • For a copy of the discussion draft regarding guidance on the profit split method, click here


3. BEPS: other news (31:51)

  • For a copy of the draft of conforming amendments to chapter IX of the OECD's Transfer Pricing Guidelines on business restructurings, click here, and for a copy of the public comments received for the discussion draft on the multilateral instrument for BEPS tax treaty measures, click here


4. Asia Pacific (36:28)

  • China, India
  • For a copy of the Indian Income Tax Rules regarding the indirect share transfer provision, section 9(1)(i), click here


5. Europe (41:44)

  • EU, Spain, UK
  • For a copy of the EUꞌs TAXE II committee report: "Tax Challenges in the Digital Economy", click here


6. Treaties (40:09)

  • Algeria / UK, Armenia / Germany, China / Romania, Romania / Uzbekistan, UAE / Uruguay

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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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- 1 July 2016
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