The authors discuss the tax treatment of hybrid financial instruments in light of the discussion draft proposals of the OECD, the proposal to amend the Parent-Subsidiary Directive (2011/96) and recent case law in the Netherlands.
The authors discuss the tax treatment of hybrid financial instruments in light of the discussion draft proposals of the OECD, the proposal to amend the Parent-Subsidiary Directive (2011/96) and recent case law in the Netherlands.