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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Taxation of Hybrid Financial Instruments and the Remuneration Derived Therefrom in an International and Cross-border Context; Issues and Options for Reform; Foreword; Preface; Contents; List of Abbreviations; List of Figures; List of Tables; 1: Introduction; 1.1 Motivation; 1.2 Objective; 1.3 Structure; 2: Background of Financial Instruments; 2.1 Terminology of Hybrid Financial Instruments; 2.2 Fundamentals of Financial Instruments; 2.2.1 Finance Theory and Practice; 2.2.1.1 Financial Markets´ Perspective; 2.2.1.2 Corporations´ Perspective

2.2.2 Financial Accounting and Banking Regulatory Law2.2.3 Interim Conclusions; 2.3 Fundamentals of Corporate Taxation; 2.3.1 Corporate Income Taxation; 2.3.1.1 Functions of Corporate Taxation; 2.3.1.2 Tax Treatment of Dividends and Interest Payments; Relationship Between Financial and Tax Accounting; Dividends; Interest Payments; 2.3.2 International Corporate Taxation; 2.3.2.1 Residence- and Source-Based Taxation; 2.3.2.2 Tax Treatment of Dividends and Interest Payments in an International Context; Dividends; Interest Payments; 2.3.3 Interim Conclusions

3: Guidelines for Corporate Income Taxation of Hybrid Financial Instruments3.1 Guiding Tax Principles; 3.1.1 Efficiency and Neutrality; 3.1.2 Inter-taxpayer Equity; 3.1.3 Inter-nation Equity; 3.1.4 EU Law; 3.1.5 Administration and Compliance Costs; 3.1.6 Interim Conclusions: Single Taxation and Simplicity; 3.2 Characteristic-Based Classification Framework; 3.2.1 No Elimination of the Debt/Equity Distinction; 3.2.2 Determination of Distinctive Characteristics; 3.2.3 Ideal-Typical Characteristics of Debt and Equity Capital; 3.2.4 Interim Conclusions

4: Tax Classifications and Treatments of Hybrid Financial Instruments and the Remuneration Derived Therefrom4.1 General Remarks; 4.1.1 Company Law and Financial Accounting and Their Relation to Tax Classifications; 4.1.2 Tax Classification in a Cross-Border Context; 4.1.3 Characteristic Approach of Tax Classifications; 4.2 International and Cross-Country Comparison of Selected EU/OECD Member States; 4.2.1 Common Remarks; 4.2.1.1 Income Tax Treaties; Introduction

Tax Consequences of the Remuneration Derived from Financial Instruments Classified as Interest-Generating Debt or Dividend-Generating EquityTax Classification of Hybrid Financial Instruments and the Remuneration Derived Therefrom; Interpretation of Income Tax Treaties; Equity Test; Debt Test; Interim Conclusions; 4.2.1.2 EU Directives and Other EU Initiatives; EU Parent-Subsidiary Directive and EU Interest and Royalties Directive; Introduction

Scope of Application and Tax Consequences of the Remuneration Derived from Financial Instruments Classified as Interest-Generating Debt or Dividend-GeneratingEquity

10.1007/978-3-642-32457-4 [DOI]

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