Dbriefs Bytes Central
9 June 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: 9 June 2017
9 June 2017
1. BEPS Multilateral Convention (00:37)
1.1 Introduction (00:45)
1.2 Treaty abuse (02:29)
1.3 PE definition (03:34)
1.4 Mandatory binding arbitration (06:09)
1.5 Other comments (06:36)
- To access the link to the OECD's database containing the signatories' lists of reservations and notifications, click here, and to the OECD's webcast on the Multilateral Convention, click here
2. PPT Examples (07:23)
2.1 Introduction (07:31)
2.2 Example H (08:43)
2.3 Example I (15:26)
3. Cases (19:23)
3.1 Norway: Hess (19:45)
3.2 India: Krishak Bharati (25:50)
4. Asia Pacific (32:30)
- Australia, Bangladesh, China, Hong Kong, India
- For a copy of
5. Europe (37:24)
- Germany, Italy, Switzerland
6. Africa (40:21)
- Ghana, Mozambique
7. Middle East & Central Asia (42:03)
8. Americas (43:18)
- Ecuador, US
9. Treaties (44:47)
- Cape Verde / Spain, Turkey / Uzbekistan
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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