Sven-Eric Bärsch
Broschiertes Buch

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

Issues and Options for Reform

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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 se...