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

Sven-Eric Bärsch ()
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Sven-Eric Bärsch: University of Mannheim

Chapter Chapter 4 in Taxation of Hybrid Financial Instruments and the Remuneration Derived Therefrom in an International and Cross-border Context, 2012, pp 87-239 from Springer

Abstract: Abstract As has been pointed out above, the remuneration derived from financial instruments is treated dichotomously for corporate income tax purposes, either as dividend-generating equity or as interest-generating debt. Furthermore, all financial instruments can be distinctively characterized by their legal rights and obligations, as can hybrid financial instruments.

Keywords: Hybrid Financial Instruments; Testing Debt; Royalties Directive; Capital Borrowing; OECD Model (search for similar items in EconPapers)
Date: 2012
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DOI: 10.1007/978-3-642-32457-4_4

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