Dbriefs Bytes Central
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
Our current Dbriefs Bytes is 18 August, and our next Dbriefs Bytes will be broadcast on 25 August.
Dbriefs Bytes: 18 August 2017
18 August 2017
1. 2017 OECD Model Treaty and Commentary: draft amendment (00:44)
- To obtain a copy of the published comments on the draft amendments to the 2017 OECD Model Treaty and Commentary, click here
2. PPT Examples (03:09)
2.1 Introduction (03:17)
2.2 Example J (05:46)
3. Cases (20:34)
3.1 US: Starr International (20:47)
3.2 UK: DS Jersey (29:47)
4. Asia Pacific (39:29)
- China, Indonesia, New Zealand
- For a copy of
5. Europe (45:27)
- EU, Germany, Russia, Slovakia
- For a copy of
- European Commission's draft report on use of economic valuation techniques in transfer pricing, click here
- Russia's guidelines to lower courts regarding various inbound investment topics (in Russian), click here
- Slovakia's government announcement regarding the introduction of amending legislation to implement various parts of the EU's anti-tax avoidance directive, a patent box regime, and a virtual PE rule in regard to digital platforms (in Slovak)n, click here
6. Americas (47:58)
- Brazil, Panama, US
- For a copy of
7. Treaties (50:26)
- MLI: Nigeria, Andorra / UAE, China / Romania, Egypt / Saudi Arabia
- Chevron's Australian transfer pricing case on intra-group debt: Chevron has withdrawn its application for special leave to appeal to the High Court. Thus, the Full Federal Court decision will stand
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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