22 December 2017




Dbriefs Bytes show

Summary: 1. US tax reform (00:39) 1.1 Corporate income tax rate, domestic dividends, and alternative minimum tax (AMT) (06:16) 1.2 Interest and net operating loss (NOL) deductions (02:38) 1.3 Full expensing of qualified property (05:58) 1.4 100% deduction for foreign dividends: "participation exemption" (06:58) 1.5 Deemed repatriation (09:08) 1.6 Intangible income: Global intangible low-taxed income (GILTI) (10:44) 1.7 Intangible income: Foreign-derived intangible income (FDII) (16:39) 1.8 Base erosion and anti-abuse tax (BEAT) (21:52) 1.9 Interest and royalties: outbound hybrid payments (26:13) 1.10 Alignment with BEPS Project (27:05) 1.11 Reading materials (29:27) • To obtain a copy of the Tax Cuts and Jobs Act and conference report, as well as our Tax Alerts on this topic, visit www.deloitte.com/ap/dbriefs/bytescentral 2. OECD (29:54) • For a copy of Second batch of stage 1 peer review reports regarding BEPS Action 14 minimum standards concerning MAP, and 4 "best practices" reports, and Online 2017 condensed version of OECD Model Treaty and Commentary, visit www.deloitte.com/ap/dbriefs/bytescentral 3. Asia Pacific (31:50) • Australia, India, Japan, Malaysia • For a copy of – Australia’s guidance in regard to the diverted profits tax, and our Tax Alert on this topic – Final version of Australia’s risk assessment approach for cross-border related party debt funding, and our Tax Alert on this topic – India’s GST Council statement regarding implementation of a nationwide e-way bill system for inter-state movement of goods – Our Tax Alert regarding Japan’s 2018 tax reform proposals – Malaysia’s explanatory note in regard to recent changes concerning withholding tax on services performed outside of Malaysia – Visit www.deloitte.com/ap/dbriefs/bytescentral 4. Europe (40:02) • Denmark, ECJ, EU, Luxembourg, UK • For a copy of – Denmark's court decision in regard to Art. 5 (in Danish) – European Court of Justice's decision in Avon Cosmetics case – European Commission's announcement on its State Aid investigation in regard to two Netherlands private rulings given to a Dutch company within the IKEA group – Luxembourg's guidance on certificate of tax residence for investment funds (in French) and our Tax Alert on this topic – UK Upper Tribunal decision in English Holdings (BVI) Ltd case – Visit www.deloitte.com/ap/dbriefs/bytescentral 5. Africa (47:03) • Ghana, South Africa • For a copy of South Africa’s new draft carbon tax bill and explanatory memorandum, visit www.deloitte.com/ap/dbriefs/bytescentral 6. Treaties (48:11) • Croatia / Kosovo, France / Portugal, Qatar / Spain, Switzerland / UK, MLI : Jersey