Special Discounts for Newly Called & Students
Browse Secondhand Online
Hybrid Financial Instruments, Double Non-taxation and Linking Rules focuses on the analysis of double non-taxation stemming from hybrid financial instruments (HFIs) and the solution provided by the Organisation for Economic Co-operation and Development (OECD) and the European Union (EU) tackling double non-taxation related to cross-border HFIs. 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 OECD and the anti-avoidance initiatives of the EU. These complex rules have now become essential in international taxation.
What’s in this book:
This book deals incisively with crucial theoretical and practical issues as the following:
How this will help you:
With its detailed attention to the concept and legal nature of HFIs and double non-taxation, and 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. This book will be an important practical guide in double non-taxation that will benefit practitioners, academics and officials.