May/June 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. 3 - 2017 of the Derivatives & Financial Instruments is now available online.

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Other publications and courses available on Taxation of Financial Instruments:

Book
Asian Voices: BEPS and Beyond
Top minds in tax and transfer pricing across Asia-Pacific discuss the BEPS Project in the context of Asia’s unique conditions.
> Read more

Course
International Taxation of Banks and Financial Institutions
15-17 November 2017
Amsterdam
> Read more

Number 3 - 2017 contains the following:
ARTICLES
International
Tax Suitability as a New Regulatory Requirement
Sergio Uldry and Nina Mueller

 

International
The Engie Case: Fiscal State Aid and Mismatches in One Member State
Erisa Nuku and Hein Vermeulen
This article analyses the European Commission’s approach to State aid arising from an inconsistent application of national law that derogates from what should have been its correct interpretation, taking the Engie opening decision as the basis of the present analysis.
Italy
Direct Lending by Alternative Investment Funds: The Italian Regulatory and Tax Framework
Vittorio Salvadori di Wiesenhoff and Giovanni Meschia
Italy has a comprehensive set of regulations that allows direct lending by alternative capital providers, which include Italian and EU alternative investment funds. This article outlines the conditions and formalities that these funds must satisfy before engaging in lending transactions in Italy, along with the applicable tax regime.
Switzerland
Court Denies Tax Treaty Benefits to Long Borrower of Swiss Shares
Peter Reinarz
The Swiss Federal Administrative Court upheld a decision by the Federal Tax Administration to reject the tax treaty-based partial refund claims of a Luxembourg resident financial institution for Swiss withholding tax on dividends paid on stock exchange-listed Swiss shares which Lux Bank had borrowed from an affiliated financial institution resident in the United Kingdom.
United States
The Character and Source of Fees and Other Payments in Financial Transactions
Paul Carman
The author focuses on the US tax treatment of the character and source of payments under financial transactions – primarily with regard to the issuance or transfer of debt instruments.
Australia
Tax Information Gathering
Anton Joseph
The powers of the Commissioner to obtain information about taxpayers has been increased under two recently enacted pieces of legislation, in line with OECD proposals.
INTERNATIONAL TAXATION OF FINANCIAL INSTRUMENTS