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Guidelines for Corporate Income Taxation of Hybrid Financial Instruments

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

Author

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  • Sven-Eric Bärsch

    (University of Mannheim)

Abstract

As has been pointed out above, hybrid financial instruments are economically and legally challenging. Moreover, within the given tax rules, there is a sharp distinction for the tax consequences of the remuneration derived from debt capital and the one derived from equity capital from a cross-border corporate tax perspective. Hence, guidelines for the assessment of the corporate taxation of hybrid financial instruments and of their classification are presented in the following. They also need to be considered in terms of an optimal design of tax rules.

Suggested Citation

  • Sven-Eric Bärsch, 2012. "Guidelines for Corporate Income Taxation of Hybrid Financial Instruments," Springer Books, in: Taxation of Hybrid Financial Instruments and the Remuneration Derived Therefrom in an International and Cross-border Context, edition 127, chapter 0, pages 43-85, Springer.
    • Handle: RePEc:spr:sprchp:978-3-642-32457-4_3
    DOI: 10.1007/978-3-642-32457-4_3
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