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Derivatives & Financial Instruments
 
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Issue No. 4 - 2017 of the Derivatives & Financial Instruments is now available online.

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Number 4 - 2017 contains the following:
ARTICLES
United Kingdom
The Impact of Brexit on Taxation in the Financial Services Sector
Zoe Feller
This article considers the UK taxes which are currently influenced by membership of the European Union, the potential models for Brexit and how the different exit models will change taxes affecting the sector. It considers both the expected impact on the Exchequer and how this may influence policy-making at a broader level.
Italy
Italian FTT in Practice: Issues and Solutions
Raul-Angelo Papotti and Michele Gusmeroli

 

Spain
Restriction to the Tax Deductibility of Financial Expenses: A Spanish View
Carlos Ferrer and Paz Irazusta
Spain has introduced measures that significantly limit the deductibility of financial costs. This article goes through those limitations and makes a comparison with the EU trends.
Germany
Impact of Investment Tax Reform on Equity Funds and Real Estate Funds
Stefan Angsten
From 1 January 2018, the revised Investment Tax Act (Investmentsteuergesetz) will apply. It introduces a partial tax liability for both German and non-German investment funds on certain items of German-source income. This article describes the upcoming changes, with a particular focus on equity funds and real estate funds.
Switzerland
Swiss Supreme Court Confirms Form-over-Substance Approach in Stamp Duty Matters
Peter Reinarz

 

United States
Modification of Non-Debt Financial Instruments
Paul Carman

 

India
Regulatory and Tax Issues for India-Focussed Venture Capital Funds
Vijay Krishnamurthy
The author considers the various regulatory issues surrounding India-focussed venture capital funds at a holistic level while providing an in-depth analysis of the tax-related issues.
International
Benchmarking Approaches for Compulsorily Convertible Debentures
Sunny Bilaney
Although there is no clear guidance from the OECD or UN regarding the determination of the arm’s length price of intercompany financial transactions, the author offers two approaches to benchmarking compulsorily convertible debentures, based on economic theory and financial models.
Hong Kong
Aircraft Leasing Bill: Truly Beneficial or an Alphabet Soup?
Kenneth Yim and Aki Cheung
In March 2017, a bill providing for concessionary tax treatment on aircraft leasing activity was introduced in Hong Kong. In this article, various considerations of this bill are reviewed.
INTERNATIONAL TAXATION OF FINANCIAL INSTRUMENTS
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