Hybrid Financial Instruments in International Tax Law - Image 1

£114.79

Kluwer Law International Hybrid Financial Instruments in International Tax Law

Name: Hybrid Financial Instruments in International Tax Law
Brand: Kluwer Law International
Price: 109.99 GBP
Availability: InStock

International

Price History & Forecast

Last 84 days • 84 data points (No recent data available)

Historical

Generating forecast...

Price Distribution

Price distribution over 84 days • 2 price levels

Days at Price

Current Price

Price Analysis

Most common price: £115 (56 days, 66.7%)

Price range: £110 - £115

Price levels: 2 different prices over 84 days

Description

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 todays 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.

Product Specifications

Brand: Kluwer Law International
Format: hardcover
ASIN: 904118273X
Category: Books > Subjects > Business, Finance & Law > Law > International
Domain: Amazon UK
Release Date: 15 November 2016
Listed Since: 04 November 2016

Barcode

No barcode data available

Kluwer Law International Hybrid Financial Instruments in International Tax Law

Price History & Forecast

Price Distribution

Price Analysis

Description

Product Specifications

Barcode

Similar Products You Might Like

Kluwer Law International - Double Non-taxation and Hybrid Entities

Investment Fund Taxation: Domestic Law, EU Law, and Double Taxation Treaties (Eucotax Series on European Taxation)

International Company Taxation and Tax Planning

A Multilateral Tax Treaty: Designing an Instrument to Modernise International Tax Law (Series on International Taxation)

The Resolution of International Tax Disputes: From the Established Mechanisms Towards an Institutionalised International Instrument (Series on International Taxation)

Taxation of Foreign Direct Investment: An Introduction (Series on International Taxation)

International Taxation of Banking (Series on International Taxation, 75)

Transfer Pricing and Financing

Kluwer Law Influence of European Law on Direct Taxation

The OECD’s Global Minimum Tax and its Implementation in the EU – A Legal Analysis of Pillar Two in the Light of Tax Treaty and EU Law

Kluwer Law International - Structuring Cross-Border Transactions

Research Handbook on European Union Taxation Law (Research Handbooks in European Law series)

Advanced Issues in International and European Tax Law (Modern Studies in European Law)

Comparative Tax Law

Tax Design Issues Worldwide (International Taxation, 51)

The Determination of Corporate Taxable Income in the EU Member States

Taxation of Cross-Border Dividends Paid to Individuals from an EU Perspective: Positive and Negative Integration (Foundation for European Fiscal Studies, 10)

International Tax Aspects of Sovereign Wealth Investors: A Source State Perspective (Series on International Taxation, 67)

Wolters Kluwer - The International Tax Law Concept of Dividend

Springer - Project Financing and the International Financial Markets

Project Financing and the International Financial Markets

Transfer Pricing in Action

Jurisdiction to Tax Corporate Income Pursuant to the Presumptive Benefit Principle: A Critical Analysis of Structural Paradigms Underlying Corporate ... for Reform (International Taxation, 70)

Combating Tax Avoidance in the EU: Harmonization and Cooperation in Direct Taxation (EUCOTAX Series on European Taxation)