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Taxation of hybrid financial instruments and the remuneration derived therefrom in an international and cross-border context[electronic resource] :issues and options for reform /

紀錄類型:	書目-語言資料,印刷品 : Monograph/item
杜威分類號:	336.278332673
書名/作者:	Taxation of hybrid financial instruments and the remuneration derived therefrom in an international and cross-border context : issues and options for reform // by Sven-Eric Barsch.
作者:	Barsch, Sven-Eric.
出版者:	Berlin, Heidelberg : : Springer Berlin Heidelberg :, 2012.
面頁冊數:	xxii, 388 p. : : ill., digital ;; 24 cm.
Contained By:	Springer eBooks
標題:	Double taxation.
標題:	Convertible securities.
標題:	Economics/Management Science.
標題:	Business Taxation/Tax Law.
標題:	Private International Law, International & Foreign Law, Comparative Law.
標題:	Finance/Investment/Banking.
標題:	Public Finance & Economics.
標題:	International Economic Law, Trade Law.
ISBN:	9783642324574 (electronic bk.)
ISBN:	9783642324567 (paper)
內容註:	Introduction -- Background of Financial Instruments -- Guidelines for Corporate Income Taxation of Hybrid Financial Instruments -- Tax Classifications and Treatments of Hybrid Financial Instruments and the Remuneration Derived Therefrom -- Classification Conflicts and Options for Reform -- Conclusions.
摘要、提要註:	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
電子資源:	http://dx.doi.org/10.1007/978-3-642-32457-4

Taxation of hybrid financial instruments and the remuneration derived therefrom in an international and cross-border context[electronic resource] :issues and options for reform /
Barsch, Sven-Eric.

Taxation of hybrid financial instruments and the remuneration derived therefrom in an international and cross-border contextissues and options for reform /[electronic resource] :by Sven-Eric Barsch. - Berlin, Heidelberg :Springer Berlin Heidelberg :2012. - xxii, 388 p. :ill., digital ;24 cm.

Introduction -- Background of Financial Instruments -- Guidelines for Corporate Income Taxation of Hybrid Financial Instruments -- Tax Classifications and Treatments of Hybrid Financial Instruments and the Remuneration Derived Therefrom -- Classification Conflicts and Options for Reform -- Conclusions.

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

ISBN: 9783642324574 (electronic bk.)Subjects--Topical Terms:

393334
Double taxation.

LC Class. No.: K4475 / .B37 2012

Dewey Class. No.: 336.278332673

Taxation of hybrid financial instruments and the remuneration derived therefrom in an international and cross-border context[electronic resource] :issues and options for reform /
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