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Addressing Tax Arbitrage with Hybrid Financial Instruments

Analysing legislative action against tax arbitrage with hybrid financial instruments from a multidisciplinary perspective, this book provides valuable insight into the effects of potential approaches.
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Title:

Addressing Tax Arbitrage with Hybrid Financial Instruments

Subtitle:

A Multidisciplinary Study and Proposal for Developed and Developing Countries

Series:

Volume 54 in the Doctoral Series

Author(s):
Date of publication:
ISBN:

978-90-8722-632-9 

Type of publication:

Print Book

Number of pages:

624

Terms:

Shipping fees apply. View shipping information

Price:
EUR 120 / USD 145 (VAT excl.)
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Title:

Addressing Tax Arbitrage with Hybrid Financial Instruments

Subtitle:

A Multidisciplinary Study and Proposal for Developed and Developing Countries

Series:

Volume 54 in the Doctoral Series

 
Author(s):
Date of publication:
ISBN:

978-90-8722-633-6

Type of publication:

eBook in ePub format

Number of pages:

624

Other:

Please note: Adobe Digital Editions is required

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Price:
EUR 96 / USD 116 (VAT excl.)
Order eBook: ePub
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Title:

Addressing Tax Arbitrage with Hybrid Financial Instruments

Subtitle:

A Multidisciplinary Study and Proposal for Developed and Developing Countries

Series:

Volume 54 in the Doctoral Series

Author(s):
Date of publication:
ISBN:

978-90-8722-634-3

Type of publication:

eBook in PDF format

Number of pages:

624

Other:

This format has a fixed layout and is identical to the original print book. It is not possible to adjust font size, however, you can zoom in on a page or graphic.

Please note: Adobe Acrobat Reader is required

For further information see our eBook FAQ.

Price:
EUR 96 / USD 116 (VAT excl.)
Order eBook: PDF
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Title:

Addressing Tax Arbitrage with Hybrid Financial Instruments

Subtitle:

A Multidisciplinary Study and Proposal for Developed and Developing Countries

Series:

Volume 54 in the Doctoral Series

Author(s):
Date of publication:
ISBN:

978-90-8722-632-9

Type of publication:

Online book

Number of pages:

624

Terms:

Up to 5 users. View purchase information

Price:
EUR 120 / USD 145 (VAT excl.)
Order Online Book
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Addressing Tax Arbitrage with Hybrid Financial Instruments
Why this book?
This book analyses legislative action against tax arbitrage with hybrid financial instruments (HFIs) from a multidisciplinary perspective.
 
It begins by investigating the non-legal problems of the legal phenomenon of tax arbitrage with HFIs, which should display the concerns caused by (uncombated) tax arbitrage with HFIs. The author works out three concerns from an inter-taxpayer equity perspective, three from an inter-nation equity perspective and three from an efficiency perspective.
 
Four approaches against tax arbitrage with HFIs are then analysed. These are the OECD approach, the low-tax approach, the UN approach and the recharacterization approach. The focus is on tax arbitrage transactions with HFIs that rely on a qualification conflict and substitute transactions with financial instruments that reach the same or a similar result.
 
The approaches under analysis are assessed in view of their potential to overcome the predefined non-legal problems. Aside from this, additional considerations regarding inter-taxpayer equity, inter-nation equity and efficiency are provided. The study also takes into account the administrability of an approach and elaborates on legal dogmatic questions.
 
Having conducted an analysis of the four approaches, the author provides his own solutions. He does not propose a new approach; rather, building on the prior discussions, he aims to advise tax policymakers on what action can possibly – and sensibly – be taken. In doing so, tax policymakers in three different situations are addressed: (i) those who already decided to combat tax arbitrage with HFIs through BEPS Action 2; (ii) those who are considering combating tax arbitrage with HFIs by means of targeted (and potentially simpler) linking rules; and (iii) those who do not intend to combat tax arbitrage with HFIs through targeted rules.
 

This book is part of the IBFD Doctoral Series
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Moritz Scherleitner is a postdoctoral researcher at the University of Helsinki and affiliated with PwC Finland. His primary research interest lies in the fields of international tax policy and EU tax law.
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