Taxation Of New Financial Instruments PDF Download
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Author | : Organisation for Economic Co-operation and Development |
Publisher | : OECD |
Total Pages | : 128 |
Release | : 1994 |
Genre | : Business & Economics |
ISBN | : |
Download Taxation of New Financial Instruments Book in PDF, ePub and Kindle
Presents the results of an analysis of the application of domestic laws and tax treaties to four particular types of instruments: interest rate swaps, financial futures, options to by shares, and bonds issued at a deep discount. Explores the possibility of arriving at consistent treatment of these instruments to provide greater certainty for both tax administrators and the financial markets.
Author | : Henry D. Shereff |
Publisher | : |
Total Pages | : 424 |
Release | : 1990 |
Genre | : Business & Economics |
ISBN | : |
Download Introduction to the Taxation of Financial Instruments Book in PDF, ePub and Kindle
Author | : OECD |
Publisher | : OECD Publishing |
Total Pages | : 71 |
Release | : 1998-03-09 |
Genre | : |
ISBN | : 9264162496 |
Download The Taxation of Global Trading of Financial Instruments Book in PDF, ePub and Kindle
This publication thoroughly reviews the factual background to global trading, analyses the challenges posed to traditional taxation methods and discusses a range of policy options to tackle the problems.
Author | : Jakob Bundgaard |
Publisher | : Kluwer Law International B.V. |
Total Pages | : 498 |
Release | : 2016-11-15 |
Genre | : Law |
ISBN | : 9041183183 |
Download Hybrid Financial Instruments in International Tax Law Book in PDF, ePub and Kindle
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.
Author | : Arlene Mary Hibschweiler |
Publisher | : McGraw Hill Professional |
Total Pages | : 478 |
Release | : 2003 |
Genre | : Business & Economics |
ISBN | : 9780071396967 |
Download Investment Taxation Book in PDF, ePub and Kindle
Publisher Description
Author | : United States. Congress. Senate. Committee on Finance |
Publisher | : |
Total Pages | : 548 |
Release | : 2011 |
Genre | : Financial instruments |
ISBN | : |
Download Tax Reform and the Tax Treatment of Financial Products Book in PDF, ePub and Kindle
Author | : Antonio H. Figueroa |
Publisher | : |
Total Pages | : 22 |
Release | : 2001 |
Genre | : |
ISBN | : |
Download Taxation of New Financial Instruments Book in PDF, ePub and Kindle
Author | : Sven-Eric Bärsch |
Publisher | : Springer Science & Business Media |
Total Pages | : 406 |
Release | : 2012-12-13 |
Genre | : Business & Economics |
ISBN | : 3642324576 |
Download Taxation of Hybrid Financial Instruments and the Remuneration Derived Therefrom in an International and Cross-border Context Book in PDF, ePub and Kindle
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.
Author | : Organisation for Economic Co-operation and Development. Special Sessions on Innovative Financial Transactions |
Publisher | : Organisation for Economic Co-operation and Development |
Total Pages | : 80 |
Release | : 1998-03-03 |
Genre | : Business & Economics |
ISBN | : |
Download The Taxation of Global Trading of Financial Instruments Book in PDF, ePub and Kindle
Document released for public comment. Includes transfer pricing.
Author | : Stanley I. Langbein |
Publisher | : Warren Gorham & Lamont |
Total Pages | : |
Release | : 2001 |
Genre | : Banks and banking |
ISBN | : 9780791344675 |
Download Federal Income Taxation of Banks and Financial Institutions Book in PDF, ePub and Kindle