From “Changing the BEAT – Final regulations answer key questions, proposed regulations give new relief”
Responding to comments, the final regulations include securities lending transactions in the category of transactions that can qualify for the exception for qualified derivatives payments. Specifically, substitute payments regarding securities lending transactions qualify for the exception from treatment as a base erosion payment. Any interest payable to a related foreign person on such a transaction is, however, treated as a base erosion payment.
The full article is available at https://www.jdsupra.com/legalnews/changing-the-beat-final-regulations-90581/