March/April 2015  
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Derivatives & Financial Instruments
 
This free e-mail service informs you about the contents of the forthcoming edition of Derivatives & Financial Instruments.

Issue No. 2 - 2015 of the Derivatives & Financial Instruments is now available online.

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Number 2 - 2015 contains the following:
ARTICLES
International
Follow Up Work on BEPS Action 6: Preventing Treaty Abuse – The Position of CIVs and Non-CIV Funds Further Considered
Michiel Hoozemans and Roel de Vries

 

Finland
Debt Classification Leads to BEPS Action in Finland
Antti Laukkanen
The author analyses a recent Finnish case concerning the ability of the tax authorities to reclassify debt as equity under domestic law. The Finnish response to the OECD’s base erosion and profit shifting initiative is also considered.
International
Securities Lending: A Market Perspective on the Changing Securities Lending Landscape
Bas Castelijn and Ivo van der Veen

 

International
The Concept of Debt-Claim as the Key Distinguishing Factor between Dividend and Interest Income in the OECD Model
Gaspar Lopes Dias
This article thoroughly examines the dividend and interest provisions in Model Conventions as they apply to characterize income from cross-border instruments, considering cases of overlap and thin capitalization.
United States
The Barnes Group Case, the Step Transaction Doctrine and Substance over Form
Paul Carman
The author discusses the recent Barnes Group case, in which the taxpayers attempted to repatriate funds from Singapore by going through Bermuda. The IRS ignored two entities created as part of the transaction and treated the repatriated funds as a dividend from Singapore.
Belgium
Ruling that Tax on the Conversion of Bearer Securities into Dematerialized Securities or Registered Securities Is Incompatible with EU Law
Werner Huygen, Lieven Bultinck and Peter Vandenbussche
The authors analyse a recent ruling by the European Court of Justice regarding the incompatibility with EU law of the Belgian tax on the conversion of bearer securities into dematerialized securities or registered securities.
Australia
Hedging Transactions and the Foreign Tax Offset Regime
Anton Joseph
The foreign income tax offset regime can have a significant impact on Australian entities hedging against fluctuations in foreign currencies. The author discusses a relevant Taxation Ruling and provides examples illustrating the application of the foreign income tax offset regime.
INTERNATIONAL TAXATION OF FINANCIAL INSTRUMENTS