March/April 2017  
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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 - 2017 of the Derivatives & Financial Instruments is now available online.

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Text

Number 2 - 2017 contains the following:
ARTICLES
United Kingdom
Base Erosion and Profit Shifting Action 4: UK Banks
Tim Adam

 

Netherlands
Supreme Court Restricts the Scope of the VAT Exemption for the Management of Special Investment Funds in the Netherlands
Edwin van Kasteren
Defining the term “special investment fund” in the VAT exemption for the management of special investment funds, the Dutch Supreme Court opts to follow the referral of the Fiscale Eenheid X case and rules on the management of a pension fund executing a defined benefit scheme.
Spain
Hybrid Mismatches and the BEPS Project: A Spanish Perspective on Brazilian Juros
Miguel Loran and Esther Villa
After providing background on the treatment of hybrid mismatches under the BEPS project, the authors discuss treatment of Brazilian juros under both domestic law and the applicable income tax treaty. Rulings by Spanish courts on this subject are also analysed.
United States
Regulations Deem Debt to Be Equity and Derivative Payments to Be Dividends
Paul Carman
Two sets of regulations recently finalized by the US Treasury may significantly impact the structure of cross-border financial transactions with US exposure.
India
Introduction of Rule Limiting Interest Deduction
Sunny Bilaney
In response to recommendations under Action 4 of the OECD/G20 BEPS project, India has introduced a rule to limit the deduction of interest on related-party debt. The author analyses the new rule, illustrates its potential impact through computational examples and suggests changes to align it with the economic scenario in India.
INTERNATIONAL TAXATION OF FINANCIAL INSTRUMENTS