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Tax Arbitrage through Cross-Border Financial Engineering

ISBN13: 9789041158758
Published: March 2015
Publisher: Kluwer Law International
Country of Publication: The Netherlands
Format: Hardback
Price: £96.00

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Tax Arbitrage through Cross-Border Financial Engineering is a comprehensive exploration of tax arbitrage opportunities ensuing from financial engineering techniques with cross-border financial instruments. You’ll discover how to enhance your practice by making use of complex types of arrangements such as hybrids, synthetics, and non-traditional financial instruments, which are able to meet the criteria for favorable tax treatment in multiple jurisdictions.

Enhance your understanding, as the author brings clarity to the beguiling debate on economic substance versus legal form; examining the role of the expected-return taxation theory and proposes an objective benchmark for the taxation of financial instruments to achieve greater international tax neutrality, ultimately promoting global wealth. You’ll benefit from practical guidance to the legislative options available in a number of countries - including Australia, Belgium, Brazil, Luxembourg, Portugal, the United Kingdom and the United States.

CHAPTER 1 Introduction.
CHAPTER 2 Locating the Main Concepts.
CHAPTER 3 Discussion on the Tax Assessment of Cross-Border Financial Instruments.
CHAPTER 4 International Tax Arbitrage.
CHAPTER 5 Conclusion.
ANNEX I Maximum Rates of Withholding Tax at Source under Different Model Tax Conventions.
ANNEX II Graphic Representation of the Relation between Two Interpretations of the Notion of Debt-Claim under Tax Treaty Law.
ANNEX III Fundamental Freedoms and Compliance with European Law.
ANNEX IV Cross-Border Financial Instruments – Tax Arbitrage Chart.
Table of Jurisprudence.