Hybrid Financial Instruments In International Tax Law

Download Hybrid Financial Instruments In International Tax Law full books in PDF, epub, and Kindle. Read online free Hybrid Financial Instruments In International Tax Law ebook anywhere anytime directly on your device. Fast Download speed and no annoying ads. We cannot guarantee that every ebooks is available!

Hybrid Financial Instruments in International Tax Law

Hybrid Financial Instruments in International Tax Law
Author :
Publisher : Kluwer Law International B.V.
Total Pages : 408
Release :
ISBN-10 : 9789041183187
ISBN-13 : 9041183183
Rating : 4/5 (183 Downloads)

Book Synopsis Hybrid Financial Instruments in International Tax Law by : Jakob Bundgaard

Download or read book Hybrid Financial Instruments in International Tax Law written by Jakob Bundgaard and published by Kluwer Law International B.V.. This book was released on 2016-11-15 with total page 408 pages. Available in PDF, EPUB and Kindle. Book excerpt: Financial innovation allows companies and other entities that wish to raise capital to choose from a myriad of possible instruments that can be tailored to meet the specific business needs of the issuer and investor. However, such instruments put increasing pressure on a question that is fundamental to the tax and financial systems of a country – the distinction between debt and equity. Focusing on hybrid financial instruments (HFIs) – which lie somewhere along the debt-equity continuum, but where exactly depends on the terms of the instrument as well as on applicable laws – this book analyses their treatment under both domestic law and tax treaties. Key jurisdictions, including the EU, some of its Member States, and the United States, are covered. Advocating for a broader scope of application of HFIs as part of the financing of companies in Europe alongside traditional sources of debt and equity financing, the book addresses such issues and topics as the following: • problems associated with the debt-equity distinction in international tax law; • cross-border tax arbitrage and linking rules; • drivers behind the use and design of HFIs; • tax law impact of perpetual and super maturity debt instruments, profit participating loans, convertible bonds, mandatory convertible bonds, contingent convertibles, preference shares and warrant loans on HFIs; • financial accounting treatment; • administrative guidance; • influence of the TFEU on Member States’ approaches to classification of HFIs; • interpretation of the Parent-Subsidiary Directive by the European Court of Justice; • applicability of the OECD Model Tax Convention; and • implications of the OECD Base Erosion and Profit Shifting (BEPS) project. Throughout this book, the analysis draws upon preparatory works, case law, and legal theory in English, German, and the Scandinavian languages. In conclusion, the author considers tax policy issues, and identifies and outlines possible high-level solutions. Actual or potential users of HFIs will greatly appreciate the clarity and insight offered here into the capacity and tax implications of HFIs. The book not only examines whether existing legislation is sufficient to handle the issues raised by international HFIs, but also provides an in-depth analysis of the interaction between corporate financing and tax law in the light of today’s financial innovation. Corporate executives and their counsel will find it indispensable in the international taxation landscape that is currently coming into view, and academics and policymakers will hugely augment their understanding of a complex and constantly changing area of tax law.


Hybrid Financial Instruments in International Tax Law Related Books

Hybrid Financial Instruments in International Tax Law
Language: en
Pages: 408
Authors: Jakob Bundgaard
Categories: Law
Type: BOOK - Published: 2016-11-15 - Publisher: Kluwer Law International B.V.

DOWNLOAD EBOOK

Financial innovation allows companies and other entities that wish to raise capital to choose from a myriad of possible instruments that can be tailored to meet
Hybrid Financial Instruments, Double Non-Taxation and Linking Rules
Language: en
Pages: 384
Authors: Félix Daniel Martínez Laguna
Categories:
Type: BOOK - Published: 2019-06-12 - Publisher:

DOWNLOAD EBOOK

Double non-taxation stemming from hybrid financial instruments and the solutions provided by the OECD and the European Union for tackling such an outcome are th
OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Hybrid Mismatch Arrangements, Action 2 - 2015 Final Report
Language: en
Pages: 458
Authors: OECD
Categories:
Type: BOOK - Published: 2015-10-05 - Publisher: OECD Publishing

DOWNLOAD EBOOK

Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adop
Hybrid Financial Instruments in International Tax Law
Language: en
Pages:
Authors: Jakob Bundgaard
Categories:
Type: BOOK - Published: - Publisher:

DOWNLOAD EBOOK

International Tax Policy and Double Tax Treaties
Language: en
Pages: 433
Authors: Kevin Holmes
Categories: Double taxation
Type: BOOK - Published: 2007 - Publisher: IBFD

DOWNLOAD EBOOK

Explains the concepts that underlie international tax law and double tax treaties and provides an insight into how international tax policy, law and practice op