March/April 2018  
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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 - 2018 of the Derivatives & Financial Instruments is now available online.

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4th IBFD Africa Tax Symposium
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Number 2 - 2018 contains the following:
ARTICLES
International
Blockchain, Initial Coin Offerings and Other Developments in the Virtual Currency Market
Aleksandra Bal
In this article, the author discusses several developments in the virtual currency sector (Ethereum, smart contracts, initial coin offerings), investigates potential applications of blockchain technology and summarizes some of the recently issued opinions of tax and regulatory bodies on virtual currency.
Luxembourg/France/United Kingdom
Is That A Tax-Transparent Fund I See? On the Perks of Being a Fund Investor in Luxembourg, France and the United Kingdom
Mariia Domina-Repiquet
This article analyses a tax-transparent limited partnership model for structuring alternative investment funds in Luxembourg, France and the United Kingdom. The objective of this comparative study is to assess the modifications introduced by the recent reforms in these jurisdictions and reflect upon their competitiveness in the post-Brexit period.
Switzerland
Securities Lending and Repo Transactions: Amended Tax Regulations
Peter Reinarz and Christoph Suter

 

Netherlands
Dutch Cross-Border Rollover Relief Regarding Real Estate, from an EU Law Perspective
Hein Vermeulen and Joris Dortmans
In this article the authors discuss the implications of the ECJ’s judgment in Commission v. Germany and the exit taxation provisions of the Anti-Tax Avoidance Directive for the Dutch implementation of cross-border rollover relief.
Brazil
Brazilian Taxation of Offshore Personal Investments: Recent Trends and Challenges in the Aftermath of the Voluntary Disclosure Programme
Flavio Rubinstein and Gustavo G. Vettori
This article analyses the Brazilian compliance and tax implications of outbound portfolio investments made by Brazilian resident individuals, a timely and relevant issue in the aftermath of the recent of the Brazilian voluntary disclosure programme. The article compares the specific rules applicable to direct ownership of financial assets as opposed to personal investment companies.
Spain
The Application of Spanish CFC Rules to Investments in EU Alternative Funds: Current Overview and the Impact of the ATAD Directive
Carlos Ferrer and Paz Irazusta

 

Hong Kong
Profits Tax Exemption to Be Extended to Privately Offered Open-Ended Fund Companies in Hong Kong
Kenneth Yim and Michelle Wu

 

China (People’s Rep.)
Tax Incentives for Start-up Investments in China: New Developments
Jieyin Tang
This article is a brief introduction of and commentary on the new tax policy of start-up investments in China.
INTERNATIONAL TAXATION OF FINANCIAL INSTRUMENTS
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