Convertible Debt Instruments in International Tax Law – Part 2

This two-part article contains an in-depth analysis of a variety of convertible debt instruments from the perspective of international tax law. Part 1, which was published in European Taxation 4 (2017), covered optional convertible instruments, mandatory and reverse convertibles, contingent convertibles, warrants and option loans and provided an overview of domestic law in a number of countries. Part 2 analyses the classification and treatment of the different types of convertible debt instruments from the perspective of EU corporate tax directives and tax treaties.