Search results for: the-tax-treatment-of-financial-instruments

Tax Treatment of Financial Instruments A Survey to France Germany The Netherlands and the United Kingdom

Author : G. M. M. Michielse
File Size : 46.66 MB
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General overview of the tax treatments of various financial instruments in four important EC Member States: France, Germany, the Netherlands and the United Kingdom, showing the most important tax differences and outlining the points on which EC harmonization is the most imperative, but also the most difficult to realize.

Hybrid Financial Instruments in International Tax Law

Author : Jakob Bundgaard
File Size : 58.52 MB
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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 today’s 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.

The Income Tax Treatment of Financial Instruments

Author : Timothy Edgar
File Size : 39.98 MB
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Examines the theoretical and practical aspects of the treatment of financial instruments under a realisation-based income tax. Argues that, within such a context, a system of expected-return taxation in preferable. The argument is developed through a review of the academic literature and selected legislative regimes.

Tax Treatment of Financial Instruments in the SEACEN Countries

Author : Junggun Oh
File Size : 73.3 MB
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Financial Instruments

Author : Great Britain. Department of Inland Revenue
File Size : 76.60 MB
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Tax Treatment of Derivative Financial Instruments Under the Netherlands US Tax Treaty

Author : Raymond Looze
File Size : 45.45 MB
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This book deals with the tax treatment of derivative financial instruments in the Netherlands and the USA. The main characteristics of option-based and future based contracts including swaps, are described.

Tax Reform and the Tax Treatment of Financial Products

Author : United States. Congress. Senate. Committee on Finance
File Size : 60.14 MB
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Investment Taxation

Author : Arlene Mary Hibschweiler
File Size : 42.33 MB
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Ghosh Tax Treatment of Financial Instruments

Author : Julian Ghosh
File Size : 48.59 MB
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Provides an analysis of the various types of financial instruments and transactions. ThE book looks at each instrument or transaction in its commercial context and the appropriate tax treatment and accounting procedure to be considered.

Taxation of Investment Derivatives

Author :
File Size : 29.15 MB
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Financial instruments

Author : Great Britain. Board of Inland Revenue
File Size : 68.1 MB
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Hybrid Financial Instruments Double Non Taxation and Linking Rules

Author : Félix Daniel Martínez Laguna
File Size : 33.28 MB
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Hybrid Financial Instruments, Double Non-taxation and Linking Rules Félix Daniel Martínez Laguna Hybrid financial instruments (HFIs) are widespread ordinary financial instruments that combine debt and equity features in their terms and design and may lead to double non-taxation across borders. This important book provides a deeply informed and critical analysis and guide to the “linking rules” developed to combat double non-taxation stemming from HFIs within the framework of the Base Erosion and Profit Shifting project of the Organisation for Economic Co-operation and Development (OECD) and the anti-avoidance initiatives of the European Union (EU). These complex rules have now become essential in international taxation. The book deals incisively with crucial theoretical and practical issues as the following: Economic and legal reasons for financing business activity through debt instruments, equity instruments and/or HFIs. Qualification of financial instruments from different perspectives such as economics, corporate finance, corporate law, financial accounting law, regulatory law and tax law and their interrelation. The concept of double non-taxation as a mere outcome of parallel exercises of sovereignty by different states and the role it plays within the international debate. The concepts of tax planning, tax avoidance and the misleading concept of aggressive tax planning within a tax competition international scenario and their relation with HFIs. Comprehensive policy, legal and technical detail and explanation of the linking rules proposed by the OECD (i.e., BEPS Project Action 2) and the EU (e.g., Anti-Tax Avoidance Directive). The (in)compatibility of linking rules with existing tax treaty rules and EU primary law. The author refers throughout to relevant model convention provisions, EU case law and a vast number of references of official documentation and literature. With its detailed attention to the concept and legal nature of HFIs and double non-taxation, the critical and comprehensive analysis of the linking rules developed by the OECD and the EU, this provocative book allows to reconsider the legality of these linking rules and will quickly become a much-used problem-solving resource for policymakers, tax practitioners, tax authorities and tax academics. This book allows to rethink whether linking rules relate to a solution or create actual legal issues.

Taxation of Hybrid Financial Instruments and the Remuneration Derived Therefrom in an International and Cross border Context

Author : Sven-Eric Bärsch
File Size : 63.16 MB
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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.

Financial Instruments

Author : Great Britain. Board of Inland Revenue
File Size : 44.71 MB
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The UK Taxation of Modern Financial Instruments Transactions

Author : Derek A. Ross
File Size : 70.13 MB
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Income Tax Treatment of Financial Instruments

Author : Timothy William Edgar
File Size : 32.61 MB
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Examines the theoretical and practical aspects of the treatment of financial instruments under a realisation-based income tax. Argues that, within such a context, a system of expected-return taxation in preferable. The argument is developed through a review of the academic literature and selected legislative regimes.

Financial Instruments

Author : Great Britain. Board of Inland Revenue
File Size : 52.85 MB
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Dessins anciens Aquarelles Tableaux anciens et modernes Pastels Gravures anciennes Objets d art et d ameublement Si ges et meubles Tapisseries 2 e vente

Author :
File Size : 49.80 MB
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Tax Treatment of Financial Instruments in Germany

Author : Manuel René Theisen
File Size : 41.83 MB
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Financial Instruments

Author :
File Size : 46.22 MB
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The tax treatment of financial instruments for managing interest rate risk.