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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. 4 - 2018 of the Derivatives & Financial Instruments is now available online.

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IBFD-PwC Transfer Pricing Seminar: Mastering the IP Life Cycle - Grasping the Intangible
30 October 2018
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28-30 November 2018
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Number 4 - 2018 contains the following:


The Playing Field outside the Stadiums of the 2020 Olympics – Developments in the Japanese Financial Markets and Taxation
J.I. van Leeuwen


Hong Kong
Impact of International Tax Changes to Hong Kong and Its Reaction
Rohit Narula
To implement the minimum standards of the BEPS package promulgated by the OECD, the fundamental transfer pricing rules have been recently introduced in Hong Kong. These rules enshrine the arm’s length principle for transactions between associated persons and the attribution of profits to a non-resident person’s permanent establishment in Hong Kong in accordance with the authorized OECD approach (AOA). However, the application of AOA and other recommendations of the BEPS Project may result in different tax implications when compared with the long-standing territorial source principle of taxation in Hong Kong, which will be explored in this article.
Recent Sweeping Reforms and Innovations in the Indian Financial Markets
Vijay Krishnamurthy
Far-reaching and irreversible reforms have been introduced in the Indian financial markets in the recent past, the effect of which is transforming the elephantine Indian economy into a digital, tight-knit and integrated economy. This article provides an overview of some significant reforms.
Taxing Banking Transactions in Pakistan
Bilal Hassan
In this article, the author analyses taxes on banking transactions under the Income Tax Ordinance 2001, introduced in the wake of poor tax compliance through informal economic activity and underreporting of formal income. The article finds the impact of banking-transaction taxes on broadening the tax base, discouraging the informal economic activity and enhancing the tax revenue to be insignificant.
Taxing Time for Cryptocurrencies
Sunny Bilaney
Regulators in many countries, including India, view cryptocurrencies as a combination of a bubble and a Ponzi scheme. The Reserve Bank of India has taken steps to dissuade Indian citizens from dealing in cryptocurrencies. However, last year’s surge in the price of cryptocurrencies has lured many taxpayers into investing or trading in it. Not only is a tussle relating to the fate of cryptocurrencies in India pending before the Indian Supreme Court, the income tax implications of cryptocurrencies are also looming. This article analyses the plausible income tax implications of dealing in cryptocurrencies in India.
Trust Arrangements in Relation to CFC Rule and Anti-Tax Treaty Abuse
Freddy Karyadi and Nina Santoso
A newly issued regulation on CFC rule expands the scope of definition of “CFC” to include an indirectly owned CFC. As such, investor(s) (in this case, the Indonesian taxpayer, settlor and/or beneficiary) owning a CFC through a trust arrangement will be subject to the CFC rule. Depending on the type of the trust, the investor(s) as well as the trust may be subject to tax under this rule. The Multilateral Convention to Implement Tax Treaty-Related Measures to Prevent Base Erosion and Profit Shifting (MLI) stipulates several provisions related to trust arrangements, including with regard to taxation treatment of capital gains derived from alienation of shares or interests of entities deriving their value principally from immovable property (real property). In particular, Indonesia uses the MLI to focus on modification to taxation regulations on permanent establishments to prevent tax abuse and treaty shopping.
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