If you have difficulty viewing this message please click here - and use this code including the square brackets behind
the click here link [*link.webversion*]
   July/August 2016  
DFI Preview IBFD, Your Portal to
Cross-Border Tax Expertise
Derivatives & Financial Instruments
This free e-mail service informs you about the contents of the forthcoming edition of Derivatives & Financial Instruments.

Issue No. 4 - 2016 of the Derivatives & Financial Instruments is now available online.

Visit www.ibfd.org for more information about IBFD publications and services.

Archive | Subscribe to other Journal Previews


P.O. Box 20237
1000 HE Amsterdam
The Netherlands
Tel: 31-20-554 0176
Fax: 31-20-622 8658

Other publications and courses available on Taxation of Financial Instruments:

International Taxation Conference 2016
1-3 December 2016
Mumbai, India
> Read more

Transfer Pricing and Intra-Group Financing
23-24 February 2017
> Read more

Number 4 - 2016 contains the following:
Court Rulings on Dividend Stripping and Denial of Swiss Tax Treaty Benefits
Peter Reinarz and Francesco Carelli
Two recent judgments by the Swiss Federal Supreme Court concerned Danish resident banks that were denied refunds of Swiss withholding taxes on dividends derived from Swiss publicly traded shares on grounds of lacking beneficial ownership, even though the applicable former Denmark-Switzerland Income and Capital Tax Treaty (1973) did not explicitly mention such a requirement. The Supreme Court overruled the decisions of a lower court granting treaty benefits to the banks.
Treading Carefully through the Murky Labyrinth of Intra-Group Financial Derivatives
Anuschka Bakker and Krzysztof Łukosz


The Effective Tax Burden Analysis after Société Générale, PMT and Brisal
B.M. van der Werf
This article focuses on the rulings of the EU Court of Justice in the Société Générale, PMT and Brisal cases, concluding that a tax burden analysis between non-residents and comparable residents should take into account a broad scope of directly linked expenses as defined by the national courts, based on the expenses that are deductible for residents. A direct deduction of expenses from the withholding tax base would be in breach of the autonomy of Member States in tax matters.
EU Anti-Tax Avoidance Package: Impacts on Financial Institutions
David Fernley and Michael Moroney
The EU Anti-Tax Avoidance Package, and in particular the EU Anti-Tax Avoidance Directive, will have wide-ranging impacts on the financing and tax affairs of financial institutions. This Directive was formally adopted at the ECOFIN meeting on 21 June 2016, with implementation expected to be effective by 1 January 2019.
Investing in Italian Real Estate Assets through Collective Investment Vehicles: An Overview of Tax Implications for Foreign Investors
Vittorio Salvadori di Wiesenhoff
The author provides a comprehensive analysis of the Italian tax regime for real estate investment funds and SICAFs, focusing on both the vehicles and the investors.
Disclosure, Secrecy and the Panama Papers
Anton Joseph
The author considers recent developments in Australia that will impact reporting and disclosure by taxpayers, and the interaction with measures proposed under the OECD’s BEPS project.
Please consider the impact on the environment before printing this e-mail.