Summary: 1. US tax reform: global impact (00:44) 1.1 Impact on "hub jurisdictions" (01:05) 1.2 Impact on high tax countries (10:46) 1.3 Impact on foreign country CFC rules (13:35) 1.4 Impact of BEAT (15:05) 2. 2017 Edition of OECD Model Treaty and Commentary: Art. 5(2) & (3) (16:50) 2.1 Introduction (16:58) 2.2 Art. 5(2): status of Art. 5(2) and relationship with Art. 5(1) (17:40) 2.3 Art. 5(2): Observations/Positions on the Commentary (19:21) 2.4 Art. 5(3): fragmentation (20:01) 2.5 Art. 5(3): subcontractors and relationship with Art. 5 (1) (21:47) 2.6 Art. 5(3): measuring time (24:58) 2.7 Art. 5(3): partnerships (27:37) 2.8 Art. 5(3): Observations/Positions on the Commentary (29:48) 3. Asia Pacific (30:52) • China, India, Korea, Malaysia, New Zealand • For a copy of – China's Bulletin 1 of 2018 in regard to consumption tax on various refined oil products and the accompanying interpretation notice (in Chinese) – China's Bulletin 3 of 2018 regarding further guidance on the deferral of dividend withholding tax on certain dividends reinvested in China (in Chinese) – India's government announcement regarding amendments to its policy concerning foreign direct investments (FDI) – Korea's announcement regarding revisions to 17 tax enforcement decrees – Malaysia's MAP guidelines – New Zealand's High Court decision in Chatfield case – Visit www.deloitte.com/ap/dbriefs/bytescentral 4. Europe (40:03) • Belarus, EGC, EU, Switzerland, UK • For a copy of – EGC's decision in EDF State Aid case (in French) and EGC's summary (in English) – European Commission's announcement regarding its launch of an in-depth State Aid investigation into a special tax regime in Poland for shipyards – European Commission's proposal which would permit Member States greater flexibility in regard to the setting and application of their lower VAT rates – European Commission's proposal in regard to the special VAT scheme for small and medium-sized enterprises (SMEs) – Switzerland's Circular 13 on the tax treatment of securities lending, borrowing and repo transactions (in German) – Our Tax Alert regarding Switzerland's update on the timeline for the implementation of Corporate Tax Reform 17 – UK's guidance in regard to Serial Tax Avoidance Regime and the disclosure of tax avoidance schemes (DOTAS) – Visit www.deloitte.com/ap/dbriefs/bytescentral 5. Americas (45:46) • Ecuador, US • For a copy of US Notice 2018-05 in regard to withholding tax on substitute dividend payments, visit www.deloitte.com/ap/dbriefs/bytescentral 6. Treaties (47:36) • Cambodia / Thailand, Czech Republic / Korea, Iceland / Japan, Ireland / Kazakhstan, Qatar / Spain
