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...

Legal fictions have been included in various tax laws in many countries. In respect of tax treaties, they may give rise to various questions, such as:• Does the inclusion of a legal fiction in a national tax law after the conclusion of a tax treaty constitute tax treaty override?• Does the...