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

Issues and Options for Reform

Authors: Bärsch, Sven-Eric

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  • ISBN 978-3-642-32457-4
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  • ISBN 978-3-642-32456-7
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Softcover $189.00
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  • ISBN 978-3-642-43233-0
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About this book

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.

Table of contents (6 chapters)

  • Introduction

    Bärsch, Sven-Eric

    Pages 1-7

  • Background of Financial Instruments

    Bärsch, Sven-Eric

    Pages 9-41

  • Guidelines for Corporate Income Taxation of Hybrid Financial Instruments

    Bärsch, Sven-Eric

    Pages 43-85

  • Tax Classifications and Treatments of Hybrid Financial Instruments and the Remuneration Derived Therefrom

    Bärsch, Sven-Eric

    Pages 87-239

  • Classification Conflicts and Options for Reform

    Bärsch, Sven-Eric

    Pages 241-319

Buy this book

eBook $149.00
price for USA (gross)
  • ISBN 978-3-642-32457-4
  • Digitally watermarked, DRM-free
  • Included format: PDF, EPUB
  • ebooks can be used on all reading devices
  • Immediate eBook download after purchase
Hardcover $189.00
price for USA
valid through November 5, 2017
  • ISBN 978-3-642-32456-7
  • Free shipping for individuals worldwide
  • Usually dispatched within 3 to 5 business days.
Softcover $189.00
price for USA
valid through November 5, 2017
  • ISBN 978-3-642-43233-0
  • Free shipping for individuals worldwide
  • Usually dispatched within 3 to 5 business days.
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Bibliographic Information

Bibliographic Information
Book Title
Taxation of Hybrid Financial Instruments and the Remuneration Derived Therefrom in an International and Cross-border Context
Book Subtitle
Issues and Options for Reform
Authors
Copyright
2012
Publisher
Springer-Verlag Berlin Heidelberg
Copyright Holder
Springer-Verlag Berlin Heidelberg
eBook ISBN
978-3-642-32457-4
DOI
10.1007/978-3-642-32457-4
Hardcover ISBN
978-3-642-32456-7
Softcover ISBN
978-3-642-43233-0
Edition Number
1
Number of Pages
XXII, 390
Topics