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  September/October 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. 5 - 2015 of the Derivatives & Financial Instruments is now available online.

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Number 5 - 2015 contains the following:
ARTICLES

International

Bitcoin Transactions: Recent Tax Developments and Regulatory Responses
Aleksandra Bal
The author examines the current treatment of Bitcoin in numerous EU and non-EU countries, and analyses the opinion of the Advocate General in a Bitcoin case that is currently pending before the European Court of Justice.
International
Insurance Premium Tax: Trends and Recent Developments

Tom Hilverkus

 

Spain
New Anti-Hybrid and Anti-Abuse Tax Measures
Enric Girona
The author analyses the recent Spanish tax reform and the changes it brings to the fight against base erosion and profit shifting and other perceived abusive structures.
Netherlands
Tax Treatment of AT1 Capital
Gabriël van Gelder and Sebastian Frankenberg
The newly introduced article 29a of the Dutch Corporate Income Tax Act 1969 (CITA) deals with the Dutch tax aspects of Additional Tier 1 capital (AT1 capital). The purpose of article 29a CITA is to ensure that payments on AT1 capital are considered tax deductible at the level of the issuing party and that any income derived from AT1 capital will be taxed. The question is whether this classification is correct and whether the classification will hold in cross-border situations. The authors analyse and discuss the Dutch tax classification of AT1 capital issued by banks and insurance companies in the Netherlands.
RECENT DEVELOPMENTS
Australia
Offshore Banking Units: Welcome Changes to Applicable Rules
Anton Joseph
Recent amendments have brought changes to the Australian rules applicable to offshore banking units. The author considers the prior provisions and the impact of the amendments.
United States

The IRS Bifurcates Many Swaps with Non-Periodic Payments

Paul Carman
The author considers temporary and proposed regulations that would cause many swap transactions to be treated for US tax purposes as a swap combined with a loan.
Netherlands
Fiscale Eenheid X : The VAT Exemption on Management of Real Estate Funds
Jochum Zutt and Myrte van Berkum
On 20 May 2015, Advocate-General Kokott released her opinion in a pending case before the Court of Justice of the European Union, Fiscale Eenheid X NV. She opined that a company investing in real estate may utilize the VAT exemption for the management of special investment funds, but in order to be eligible, it must be regulated.
INTERNATIONAL TAXATION OF FINANCIAL INSTRUMENTS
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