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Taxation of hybrid financial instrum...

Barsch, Sven-Eric.

Taxation of hybrid financial instruments and the remuneration derived therefrom in an international and cross-border contextissues and options for reform /

Record Type:	Electronic resources : Monograph/item
Title/Author:	Taxation of hybrid financial instruments and the remuneration derived therefrom in an international and cross-border contextby Sven-Eric Barsch.
Reminder of title:	issues and options for reform /
Author:	Barsch, Sven-Eric.
Published:	Berlin, Heidelberg :Springer Berlin Heidelberg :2012.
Description:	xxii, 388 p. :ill., digital ;24 cm.
Contained By:	Springer eBooks
Subject:	Double taxation.
Online resource:	http://dx.doi.org/10.1007/978-3-642-32457-4
ISBN:	9783642324574 (electronic bk.)

Taxation of hybrid financial instruments and the remuneration derived therefrom in an international and cross-border contextissues and options for reform /
Barsch, Sven-Eric.

Taxation of hybrid financial instruments and the remuneration derived therefrom in an international and cross-border contextissues and options for reform /[electronic resource] :by Sven-Eric Barsch. - Berlin, Heidelberg :Springer Berlin Heidelberg :2012. - xxii, 388 p. :ill., digital ;24 cm.

Introduction -- Background of Financial Instruments -- Guidelines for Corporate Income Taxation of Hybrid Financial Instruments -- Tax Classifications and Treatments of Hybrid Financial Instruments and the Remuneration Derived Therefrom -- Classification Conflicts and Options for Reform -- Conclusions.

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

ISBN: 9783642324574 (electronic bk.)Subjects--Topical Terms:

298609
Double taxation.

LC Class. No.: K4475 / .B37 2012

Dewey Class. No.: 336.278332673

Taxation of hybrid financial instruments and the remuneration derived therefrom in an international and cross-border contextissues and options for reform /
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245 1 0 $a Taxation of hybrid financial instruments and the remuneration derived therefrom in an international and cross-border context $h [electronic resource] : $b issues and options for reform / $c by Sven-Eric Barsch.
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300 $a xxii, 388 p. : $b ill., digital ; $c 24 cm.
505 0 $a Introduction -- Background of Financial Instruments -- Guidelines for Corporate Income Taxation of Hybrid Financial Instruments -- Tax Classifications and Treatments of Hybrid Financial Instruments and the Remuneration Derived Therefrom -- Classification Conflicts and Options for Reform -- Conclusions.
520 $a 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
650 0 $a Double taxation. $3 298609
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650 1 4 $a Economics/Management Science. $3 273684
650 2 4 $a Business Taxation/Tax Law. $3 511940
650 2 4 $a Private International Law, International & Foreign Law, Comparative Law. $3 530877
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