Taxation of Hybrid Financial Instruments and the Remuneration Derived Therefrom in an International and Cross-border Context Issues and Options for Reform

Sale price  $152.99 Regular price $169.99

Taxation of Hybrid Financial Instruments and the Remuneration Derived Therefrom in an International and Cross-border Context Issues and Options for Reform

Sale price  $152.99 Regular price $169.99

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Taxation of Hybrid Financial Instruments and the Remuneration Derived Therefrom in an International and Cross-border Context

Issues and Options for Reform

Sven-Eric Bärsch

Business & Economics / Taxation / Corporate

Despite the enormous diversity and complexity of financial instruments, the current taxation of hybrid financial instruments and the remuneration derived therefrom are characterized by a neat division into dividend-generating equity and interest-generating debt as well as by a coexistence of source- and residence-based taxation. This book provides a comparative analysis of the classification of hybrid financial instruments in the national tax rules currently applied by Australia, Germany, Italy and the Netherlands as well as in the relevant tax treaties and EU Directives. Moreover, based on selected hybrid financial instruments, mismatches in these tax classifications, which lead to tax planning opportunities and risks and thus are in conflict with the single tax principle, are identified. To address these issues, the author provides reform options that are in line with the dichotomous debt-equity framework, as he/she suggests the coordination of either tax classifications or tax treatments.


Publication Date: 29 January 2015
Publisher: Springer Berlin Heidelberg
Imprint: Springer
ISBN-13: 9783642432330
Format: Paperback softback
Page Count: 390

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