May/June 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. 3 - 2015 of the Derivatives & Financial Instruments is now available online.

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Number 3 - 2015 contains the following:
The Avoidance of International Double Bank Taxation
Dennis Schäfer
The author discusses the means of avoiding double bank taxation in the Netherlands, under both domestic law and the agreement entered into with the United Kingdom for this purpose, as well as similar agreements between the United Kingdom on the one hand, and France and Germany on the other.
United States
BEPS Action 2: Hybrid Mismatch Arrangements
Paul Carman
The author provides an in-depth analysis of the OECD report on BEPS Action 2 and its potential impact on international tax planning.
Federal Government Proposes Fundamental Changes to Swiss Withholding Tax System
Peter Reinarz
The federal Finance Department has issued a proposed legislative bill that would change the tax system applicable to bond interest, from the present debtor system to a paying agent system. The author discusses this proposed change and its potential impact on both resident and non-resident recipients of bond interest.
New Controlled Foreign Corporation Rules and the Alternative Investment Fund Managers Directive
Cristina Mayo Rodriguez
The author considers the interplay between the new controlled foreign corporation rules in Spain and the EU Alternative Investment Fund Managers Directive, and the light that can be shed on this issue by case law of the European Court of Justice.
Administrative Circular on Taxation of Luxembourg Limited Partnerships Is a Welcomed First Step
Pierre-Antoine Klethi
Luxembourg partnerships have proven to be very popular, notably with foreign actors in the private equity sector. While regulated partnerships formally benefit from broad tax exemptions, unregulated ones usually submit advance tax ruling requests confirming the absence of municipal business tax liability. A new circular issued in January 2015 provides certainty in this regard for unregulated partnerships which qualify as alternative investment funds, but does not fully lift the uncertainty for the remaining ones.
Taxation of Investments on the Brazilian Capital Market: New Tax Incentives and Recent Changes
Flavio Rubinstein and Stéphanie Samaha
This article provides an overview of recent tax incentives and changes to tax rules for investments on the Brazilian capital market.