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European Union - Classification and Treatment of Hybrid Financial Instruments and Income Derived Therefrom under EU Corporate Tax Directives – Part 1

European Union
J. Bundgaard
European Taxation, 2010 (Volume 50), No 10
2 September 2010
In this two-part article, the author addresses the application of EU tax directives on hybrid financial instruments. In Part 1, the applicability of the Parent-Subsidiary Directive and the Interest and Royalties Directive is analysed. In Part 2, unilateral measures of Member States to combat cross-border arbitrage are discussed. Moreover, Part 2 contains an analysis of the holding requirements under the directives and the application of the EU Arbitration Convention.
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