Hybrid financial instruments in international tax law / Jakob Bundgaard.

Alphen aan den Rijn, the Netherlands : Wolters Kluwer, [2017]

xx, 469 pages ; 25 cm.

"dreyersfond."

"[This book] examines the tax issues affecting the use of hybrid financial instruments (HFIs). 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. This book analyzes the treatment of 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 – under both domestic law and tax treaties. Key jurisdictions, including the EU, some of its Member States, and the United States, are covered."-- Back cover.

English

August 07, 2017

Corit academic books series ; no. 6.

Includes bibliographical references (pages 417-464) and index.