Dbriefs Bytes Central
9 February 2018
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: 9 February 2018
9 February 2018
1. US tax reform (00:36)
2. 2017 Edition of OECD Model Treaty and Commentary: Art. 5(4) (03:22)
2.1 Introduction (03:30)
2.2 "Preparatory or auxiliary character": a required condition for all subparagraphs? (05:48)
2.3 "Preparatory or auxiliary character": meaning (11:16)
2.4 Subparagraphs (a) & (b) (14:17)
2.5 Subparagraph (e) (17:19)
3. Cases (19:48)
3.1 Netherlands: dual residence tie-breaker (20:04)
- For a copy of the Dutch Supreme Court decision in the dual residence tie-breaker case (in Dutch) ), click here
3.2 Australia: RCF case (30:35)
- For a copy of the Federal Court of Australia's decision in the RCF case, click here
4. Asia Pacific (46:48)
- Australia, China, Korea
- For a copy of
- Australia's draft guidelines on the operation of the diverted profits tax, click here
- Australia's consultation documents on draft legislation to give the force of law to the MLI
- China's Bulletin 9 on "beneficial ownership" (in Chinese), click here
5. Europe (49:14)
- Belarus, EU, Germany, Ireland, Norway
- For a copy of
- Our Tax Alert in regard to EU and Norway signing the VAT cooperation agreement, click here
- Documents from the European Commission's VAT Expert Group meeting
- General provisions: working document, click here
- Non-Union scheme: working document, click here
- Union scheme: working document, click here
- Draft paper on meaning of "financial, economic and organizational links" in connection with VAT groups, click here
- Draft paper on possible VAT implications of transfer pricing, click here
- Our Tax Alert on the German case in regard to the definition of the "direct shareholding" requirement under the EU parent-subsidiary directive and its implementation into German tax law, click here
- Our Tax Alert regarding the tax policies of Germany's new government coalition, click here
- Ireland's guidance regarding capital allowances for intangible assets and related interest deductions, click here
- Norway's guidance on MAP procedures, click here
6. BEPS (52:16)
6.1 Updated guidance on implementation of CbC Reporting (52:30)
- For a copy of OECD's updated CbC guidance, click here and compilation of approaches adopted by jurisdictions, click here
6.2 Updated conclusions on preferential tax regimes (53:45)
- For a copy of updated table of regime results, click here
7. Treaties (54:18)
- Barbados/Cyprus, Ghana/Ireland
BEPS: Likely impact on business models
Disregarded payment made by a hybrid (Part 2)
10 June 2016
Disregarded payment made by a hybrid (Part 1)
3 June 2016
Payments made to a reverse hybrid
15 April 2016
Cost contribution arrangements
8 April 2016
Downloadable digital products: source country taxation
19 February 2016
Internet advertising: source country taxation
12 February 2016
5 February 2016
15 January 2016
PE aspects of toll manufacturing
8 January 2016
Centralized purchasing or procurement, using an agency model
18 December 2015
Centralized purchasing or procurement, using a buy / sell model
4 December 2015
Calculation of the profits attributable to an Article 5(5) agency PE
27 November 2015
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