12 January 2018




Dbriefs Bytes show

Summary: 1. US tax reform (00:44) 1.1 What's in a name? (01:02) 1.2 Territorial system vs. full inclusion system (with foreign tax credits) (02:37) 1.3 GILTI: impact of foreign tax credits (06:51) 1.4 GILTI: impact of limited taxable income (09:45) 1.5 FDII (10:49) 1.6 BEAT (11:57) 1.7 Documents (15:14) • To obtain a copy of – Notice 2018-07 – Notice 2018-08 – Slide deck from US Dbriefs webcast – Visit www.deloitte.com/ap/dbriefs/bytescentral 2. Digital Taxation (16:17) 2.1 Taiwan (16:35) 2.2 Italy (21:26) 2.3 Slovakia (22:10) • For a copy of – Taiwan's ruling regarding new rules on Taiwan-source income derived by non-resident suppliers (in Chinese) and our Tax Alert on the topic, visit www.deloitte.com/ap/dbriefs/bytescentral 3. Asia Pacific (23:10) • Australia, China, Hong Kong, Philippines, Thailand • For a copy of – Australia's government statement regarding deferral of the simplification of TOFA rules (taxation of financial arrangements) – China's Circular 88 (in Chinese) – China's Circular 84 (in Chinese) – Hong Kong's proposed legislation and related government statements regarding the introduction a BEPS-compliant transfer pricing regime – Philippines government announcement regarding the introduction of proposed legislation to significantly change the corporate income tax system – Our Tax Alert on Thailand's proposed legislation to introduce a formal transfer pricing regime – Visit www.deloitte.com/ap/dbriefs/bytescentral 4. Europe (31:21) • Belgium, Denmark, ECJ, EU, France, Ireland, Italy, Netherlands, Russia, Serbia • For a copy of – Denmark's ruling in regard to the characterisation, for Danish tax purposes, of an Irish Common Contractual Fund (a CCF) (in Danish) – European Court of Justice's decision in Deister and Juhler case – European Court of Justice's decision in Hamamatsu Photonics Deutschland case – EU's three directives dealing with the reform of the VAT rules on e-commerce • 2017/2455 • 2017/2459 • 2017/2454 – European Commission's draft directive to make permanent the minimum 15% standard VAT rate – Our Tax Alert regarding France's second amended finance bill for 2017 and finance bill for 2018 – Ireland's guidance in regard to the definition of trade – Our Tax Alert regarding Italy's budget law for 2018 – Dutch Supreme court decision regarding fiscal unity between Dutch subsidiaries of Israeli parent company (in Dutch) – Visit www.deloitte.com/ap/dbriefs/bytescentral 5. Africa (42:45) • South Africa • For a copy of South Africa's draft guidance in regard to section 23I, which denies deductions in regard to certain "tainted" intellectual property, visit www.deloitte.com/ap/dbriefs/bytescentral 6. Middle East & Central Asia (43:46) • Gulf Cooperation Council countries, Uzbekistan 7. Americas (46:14) • Argentina, Brazil, Mexico • For a copy of – Our Tax Alerts on the developments in Brazil with regard to the tax treatment of software transactions • Remittances made for right to distribute software deemed to be royalties • State of Sao Paulo issues new rules on levy of state VAT on software – Our Tax Alert regarding Mexico's Special Economic Zones – Visit www.deloitte.com/ap/dbriefs/bytescentral 8. Treaties (49:07) • Armenia / Germany, Cambodia / Singapore, Chad / Turkey, Cyprus / Saudi Arabia, Germany / Turkmenistan, Ghana / Netherlands, Hong Kong / Pakistan, Singapore / Sri Lanka