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
      • International Tax Agreements Amendment (Multilateral Convention) Bill 2018
        • Exposure draft, click here
        • Explanatory memorandum, click here
    • 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

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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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- 2 February 2018
26 January 2018
- 19 January 2018
- 12 January 2018
- 22 December 2017
- 15 December 2017
- 24 November 2017
- 17 November 2017

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