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Classification Conflicts and Options for Reform

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

Chapter Chapter 5 in Taxation of Hybrid Financial Instruments and the Remuneration Derived Therefrom in an International and Cross-border Context, 2012, pp 241-319 from Springer

Abstract: Abstract As has been pointed out above, there is a significant lack of consistency in the currently applicable tax classifications of hybrid financial instruments and the remuneration derived therefrom between the examined countries themselves. In principle, this is based on the distinctive characteristics of these instruments which are differently decisive for the purposes of domestic law, income tax treaties and EU Directives.

Keywords: Source Country; Double Taxation; Preference Share; Debt Instrument; Relevant Combination (search for similar items in EconPapers)
Date: 2012
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Persistent link: https://EconPapers.repec.org/RePEc:spr:sprchp:978-3-642-32457-4_5

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DOI: 10.1007/978-3-642-32457-4_5

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