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Dbriefs Bytes

Dbriefs微播

Dbriefs Bytes brings you a weekly summary of the significant international tax developments impacting Asia Pacific. This video is broadcast every Friday afternoon. Stay tuned! 

Dbriefs Bytes is presented by Steve Towers, Asia Pacific Leader - International Tax.

Our next regular Dbriefs Bytes will be broadcast on 22 August.


Latest Dbriefs Bytes

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15 August 2014

  1. Korea
    • Tax rate increase to encourage large Korean companies to reduce their cash balances by spending on investment, increased wages, dividends, etc.
    • Two calculation methods
    • For a copy of 6 August 2014 government press release, click here
    • For a copy of July 2014 government document on economic policies, click here
    • For information: Gyung Ho Kim (Seoul)
  1. Cases
    • India
      • Zaheer: characterization of profit made on the sale of debentures: "interest" or "capital gain"?
      • LG: does Korean parent have a PE in India (at the premises of Indian subsidiary)?
      • Reuters: definition of "royalties" in India / UK treaty
      • For information: N.C. Hegde (Mumbai) or K.R. Sekar (Bangalore)
    • Finland
  1. Inversions
    • Biggest international tax story of 2014?
    • Why are there many more inversions now?
  1. China
    • Circular 318: enforcement of capital gains tax on share transfers
    • Draft GAAR guidelines: comments from Tax Executive Institute (TEI)
      • For a copy of TEI's comments, click here
    • For information: Vicky Wang (Shanghai) or Ye Hong (Shanghai)
  1. In brief
    • Treaties: Korea / Colombia and China / Netherlands treaties enter into force
    • OECD
      • Request for public comments on BEPS Action 11: for a copy, visit BEPS Central
      • Part 1 of report on the impact of BEPS on low-income countries: for a copy, visit BEPS Central
      • Global Forum's latest batch of peer reviews and compliance ratings, in regard to transparency and exchange of information
        • For a copy of Indonesia's report, click here
    • New Zealand: tax authority's description of recent changes to thin cap rules
    • Whistleblowers

 

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1 August 2014

  1. OECD Model Treaty and Commentary: 2014 Update: Share redemptions
    • Source country treatment as "income from shares" requires that Article 10, not 13, applies
    • Residence country must accept that treatment, for purposes of Articles 23A and 23B
  1. OECD Model Treaty and Commentary: 2014 Update: Accrued interest
    • Definition of "interest" in Article 11
    • Amended Commentary: sale of security for price which reflects accrued interest, redemption premium, or original issue discount
  1. OECD Model Treaty and Commentary: 2014 Update: "Look through" rule for conduit companies?
    • Amendments to Model Treaty and Commentary in regard to "beneficial ownership" do not provide for an express "look through" rule for conduit companies
  1. Cases
    • India: MISC case
    • Article 8 of India / Malaysia treaty
    • Slot-chartering arrangement
    • For information: N.C. Hegde (Mumbai) or K.R. Sekar (Bangalore)
  1. In brief
    • Treaties
      • Singapore / Liechtenstein enters into force
    • Taiwan
      • R&D tax credits and other incentives: now require compliance with environmental, labor, and food safety laws
      • For information: Cheli Liaw (Taipei)
    • India
      • Cairn: moves its "indirect share transfer" case to new committee
      • For information: N.C. Hegde (Mumbai) or K.R. Sekar (Bangalore)

25 July 2014

  1. OECD Model Treaty and Commentary: 2014 Update
    • Omitted: amendments to Commentary on Article 5
    • Amendments to Commentary on meaning of "beneficial owner"
      • "Dependent" test vs. "related" test
    • For a copy of the 2014 Update, click here
  1. Cases
    • Allcargo Global Logistics (India)
      • Re-characterize transaction for transfer pricing purposes
      • Tribunal: delayed allotment of shares cannot be re-characterized as a loan
      • For information: K.R. Sekar (Bangalore)
  1. Australia
    • Carbon tax repealed
    • Amendment bill: thin capitalization and participation exemption for non-portfolio foreign dividends
    • Internal ATO report
    • For information: David Watkins (Sydney)
  1. BEPS
    • Pascal Saint-Amans: testimony to U.S. Senate Committee on Finance
      • For a copy of the testimony, click here
    • Michelle Levac: interesting comments on "special measures"
  1. In brief
    • Treaties
      • Signed: Taiwan / Austria
      • In force: India / Poland protocol
    • OECD: new global standard for automatic exchange of information
      • For a copy of the global standard, click here
    • Vietnam: Circular 78
    • Indonesia: new President

11 July 2014

  1. Cases
    • Kerala Vision
      • Retrospective amendments to definition of "royalties"
      • Impact on tax deduction for relevant payments
      • For information: K.R. Sekar (Bangalore)
    • Antwerp Diamond Bank
      • Retrospective amendments to definition of "royalties"
      • Application to treaty definition?
      • For information: Rajesh Gandhi (Mumbai)
    • IATA BSP
      • Application of "most favored nation" clause in treaty
      • For information: K.R. Sekar (Bangalore)
  1. Shanghai Pilot Free Trade Zone
    • 2014 "negative list" for foreign investors
    • Overall, a relaxation
    • For a copy of the 2014 "negative list" (Chinese language), click here
    • For information: Vicky Wang (Shanghai) or
      Ye Hong (Shanghai)
  1. Transfer pricing: Malaysia and Vietnam
    • Malaysia
      • Questions on income tax return form
      • Questionnaire (called "transfer pricing awareness survey")
      • For a copy of the questionnaire, click here
      • For information: Tan Hooi Beng (Kuala Lumpur)
    • Vietnam
      • Revised transfer pricing information form
      • For a copy of revised form, click here
      • For information: Tom McClelland (Ho Chi Minh)
  1. FATCA and CRS
    • FATCA (Foreign Account Tax Compliance Act) starts!
      • For FATCA article in World Tax Advisor, click here
    • CRS (Common Reporting Standard)
      • Australia issues discussion paper, for comment
      • For a copy of discussion paper, click here
  1. In brief
    • Japan: Shiseido
      • Transfer pricing assessment
    • BEPS: Spain's unilateral actions
    • U.S. officials resign
    • Brazil: change of treaty interpretation
    • China
      • Bulletin 38: CFC rules
      • Draft guidance on GAAR (comments requested by 1 August 2014)
      • For information: Vicky Wang (Shanghai) or
        Ye Hong (Shanghai)
    • India: corporate social responsibility
      • For a copy of government circular, click here
      • For information: K.R. Sekar (Bangalore)
    • Indonesia: Presidential election

4 July 2014

  1. Cases
    • Kerala Vision
      • Retrospective amendments to definition of "royalties"
      • Impact on tax deduction for relevant payments
      • For information: K.R. Sekar (Bangalore)
    • Antwerp Diamond Bank
      • Retrospective amendments to definition of "royalties"
      • Application to treaty definition?
      • For information: Rajesh Gandhi (Mumbai)
    • IATA BSP
      • Application of "most favored nation" clause in treaty
      • For information: K.R. Sekar (Bangalore)
  1. Shanghai Pilot Free Trade Zone
    • 2014 "negative list" for foreign investors
    • Overall, a relaxation
    • For a copy of the 2014 "negative list" (Chinese language), click here
    • For information: Vicky Wang (Shanghai) or
      Ye Hong (Shanghai)
  1. Transfer pricing: Malaysia and Vietnam
    • Malaysia
      • Questions on income tax return form
      • Questionnaire (called "transfer pricing awareness survey")
      • For a copy of the questionnaire, click here
      • For information: Tan Hooi Beng (Kuala Lumpur)
    • Vietnam
      • Revised transfer pricing information form
      • For a copy of revised form, click here
      • For information: Tom McClelland (Ho Chi Minh)
  1. FATCA and CRS
    • FATCA (Foreign Account Tax Compliance Act) starts!
      • For FATCA article in World Tax Advisor, click here
    • CRS (Common Reporting Standard)
      • Australia issues discussion paper, for comment
      • For a copy of discussion paper, click here
  1. In brief
    • Japan: Shiseido
      • Transfer pricing assessment
    • BEPS: Spain's unilateral actions
    • U.S. officials resign
    • Brazil: change of treaty interpretation
    • China
      • Bulletin 38: CFC rules
      • Draft guidance on GAAR (comments requested by 1 August 2014)
      • For information: Vicky Wang (Shanghai) or
        Ye Hong (Shanghai)
    • India: corporate social responsibility
      • For a copy of government circular, click here
      • For information: K.R. Sekar (Bangalore)
    • Indonesia: Presidential election

27 June 2014

  1. BEPS
    • OECD's Committee on Fiscal Affairs
    • Unilateral changes: Sweden (interest)
    • EU investigations of Apple, Starbucks, and Fiat
    • IMF: "Spillovers in international corporate taxation"
    • U.S. State taxation: formulary apportionment
  1. Japan
    • Abenomics: "third arrow" plan
    • Proposed corporate income tax rate cuts
    • For information: Jun Takahara (Tokyo)
  1. Cases
    • India: Shaan Marine Services
    • Pune Income Tax Appellate Tribunal
    • Article 8 of India / Cyprus treaty
    • For information: K.R. Sekar (Bangalore)
  1. India
    • Budget scheduled for 10 July
    • Tax Administration Reform Commission (TARC) report: significant criticism
      • To obtain a copy of the report, click here
    • Switzerland: list of Indian tax evaders
    • For information: K.R. Sekar (Bangalore)
  1. China
    • Guangdong: two related "indirect share transfer" cases
    • Circular 56: VAT incentives for film industry
    • For information: Vicky Wang (Shanghai) or
      Ye Hong (Shanghai)
  1. In brief
    • Inversions
    • Singapore: new liquidity requirements for banks
    • UN: questionnaire on Article 13(4)
      • To obtain a copy of the questionnaire, click here
    • Netherlands fiscal unity
    • So long, Mike Danilack
    • Maldives

 

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Disclaimer Note

Please note that the comments made in this presentation, to some extent, are based on material obtained from sources outside Deloitte.

This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms, or their related entities (collectively, the "Deloitte network") is, by means of this communication, rendering professional advice or services. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication.

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