Institutional Hybrid Financial Instruments And Double Non Taxation Under Domestic Rules And Tax Treaty Law The Example Of Spain

Download or read book Institutional Hybrid Financial Instruments and Double Non-taxation Under Domestic Rules and Tax Treaty Law : the Example of Spain written by F.D. Martínez Laguna and published by . This book was released on 2016 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: Attention has been paid to double non-taxation resulting from contractual hybrid financial instruments, which are instruments that share debt and equity features. This article focuses on a specific Institutional Hybrid Financial Instrument instead. Institutional Hybrid Financial Instruments are equity instruments that could equally lead to conflicts of qualification and double non-taxation considering the deductibility from a tax perspective according to a tax policy decision. The analysis deals with the application of the Spanish exemption method to Brazilian Juros sobre o Capital Próprio from a domestic law and tax treaty perspective. Moreover, the implementation of linking rules and its implications regarding hybrid financial instruments are also considered.