March/April 2016  
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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 - 2016 of the Derivatives & Financial Instruments is now available online.

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Other publications and courses available on Taxation of Financial Instruments:

[Conference]
70th Congress of the International Fiscal Association
25-30 September 2016
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[Course]

Trusts and Estate - International Tax Planning
12-14 October 2016
Amsterdam
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Number 2 - 2016 contains the following:
ARTICLES
International
Treaty Entitlement of Investment Funds in Light of BEPS Actions 2 and 6
Daniel W. Blum and Erik Pinetz
Both the limitation-on-benefits clause and the principal purpose test proposed by the OECD in its current BEPS initiative aim at countering treaty shopping. A closer look reveals that these rules could have considerable effect on the tax treaty entitlement of investment funds. In this article the authors shed light on the provisions proposed so far, their interplay with the proposed article 1(2) of the OECD Model and their effects on the treatment of investment funds under international tax law.
International

The VAT Exemption for the Management of Special Investment Funds: A Never Ending Journey? – Decision of the EU Court of Justice in the Fiscale Eenheid X Case

Edwin van Kasteren

Although the journey towards fully understanding the wider implications of the VAT exemption for the management of special investment funds is a long and complicated one, a recent decision of the European Court of Justice sheds light on the path forward.

Mexico
New Mandatory Clearing and Settling Rules for “Standardized Derivative Transactions”
Javier Diaz de Leon Galarza
The author clarifies transactional and regulatory aspects of standardized derivative transactions, based on new tax provisions.

Spain

Tax Treatment of Cross-Border Investment Management
Cristina Mayo
The General Directorate of Taxation has given an important boost to the cross-border management of investment vehicles by Spanish management companies, by issuing a binding consultation that clarifies the tax treatment thereof.
Australia
New Regime for Managed Investment Trusts
Anton Joseph
Taxation of trusts in Australia has been tangled for a very long time in a web of English law concepts of equity and later statutory intervention. The author discusses amendments to income tax law that are basically focussed on adopting an income attribution method for determining the tax liability of trust beneficiaries.
INTERNATIONAL TAXATION OF FINANCIAL INSTRUMENTS