March/April 2015  
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. 2 - 2015 of the Derivatives & Financial Instruments is now available online.

Visit 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:


Number 2 - 2015 contains the following:
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


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.
Securities Lending: A Market Perspective on the Changing Securities Lending Landscape
Bas Castelijn and Ivo van der Veen


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.
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.
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.