Dbriefs Bytes Central

8 September 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: 8 September 2017

8 September 2017

1. IFA Congress: BEPS & Other Topics (00:42)


2. UN Tax Experts Committee (03:43)


3. CbC reporting (04:55)

3.1 Updated guidance on implementation of CbC Reporting (05:11)

3.2 Guidance on the appropriate use of information in CbC Reports (09:46)

  • For a copy of the OECD's updated guidance on implementation of CbC Reporting, click here, and guidance on the appropriate use of information in CbC Reports, click here


4. Denmark: PE rulings (11:43)

4.1 Article 5(1): Sub-contracting of cleaning and maintenance services (12:01)

4.2 Article 5(1) & (4): information collection and marketing activities (18:33)

4.3 Article 5(1): home office (21:06)


5. Asia Pacific (24:22)

  • Australia, India, Taiwan
  • For a copy of
    • Australia's package of documents regarding the Asia Region Funds Passport and the Corporate Collective Investment Vehicle (CCIV)
      • Asia Region Funds Passport Draft Bill, click here
      • Asia Region Funds Passport Explanatory Material, click here
    • Our Tax Alert regarding Taiwan's recent proposed tax changes, click here


6. Europe (29:13)

  • Denmark, EU, Italy, Montenegro, Netherlands, Romania, Sweden, Switzerland, UK
  • For a copy of
    • European Commission's consultation document regarding inefficiencies in the EU capital market, click here
    • Italy's protocol regarding implementation rules for the foreign branch exemption regime (in Italian), click here
    • Our Tax Alert regarding the Netherlands's VAT reverse charge on B2B supplies of telecommunication services, click here
    • Sweden's press release regarding the abolition of its advertising tax on advertising revenue of certain newspapers (in Swedish), click here
    • Relevant documents regarding Switzerland's consultation in regard to TP 17, click here and here
    • UK First-Tier Tribunal's decision on VAT case regarding the fund management industry, click here


7. Middle East & Central Asia (34:55)

  • Israel, Lebanon, GCC countries
  • For a copy of UAE's decree law, click here
  • To access Saudi Arabia's online VAT registration portal, click here


8. Americas (36:54)

  • Brazil, Chile, US
  • For a copy of
    • Our Tax Alert regarding Brazil's private ruling addressing the reimbursement of remuneration costs paid by a foreign head office or affiliate, click here
    • Our Tax Alert regarding Brazil's guidance on withholding tax rates which apply to capital gains derived by non-resident entities on the disposal of Brazilian assets, click here
    • WTO decision regarding Brazil's tax incentive programs, click here
    • WTO decision regarding tax incentives provided by Washington state, click here


9. Treaties (42:04)

  • Cambodia / Thailand, Cameroon / South Africa, Estonia / Japan, Japan / Russia, Jordan / Saudi Arabia, Switzerland / Zambia

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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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- 25 August 2017
- 18 August 2017
- 11 August 2017
28 July 2017
- 14 July 2017
- 7 July 2017
- 23 June 2017
- 16 June 2017

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