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European Union - Classification and Treatment of Hybrid Financial Instruments and Income Derived Therefrom under EU Corporate Tax Directives – Part 2

Country:
European Union
Author:
J. Bundgaard
Issue:
European Taxation, 2010 (Volume 50), No 11
Published:
1 October 2010
In this two-part article, the author addresses the application of EU tax directives to hybrid financial instruments. In Part 1, the applicability of the Parent-Subsidiary Directive and the Interest and Royalties Directive was analysed. In Part 2, unilateral measures of Member States to combat cross-border arbitrage are discussed. Moreover, Part 2 contains an analysis of the fulfilment of the holding requirements under the directives and the application of the Arbitration Convention.
 
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