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Hybrid finance and double taxation treaties

Authors: M. Six;

Hybrid finance and double taxation treaties

Abstract

Company finance is traditionally divided into equity and debt, but this does not truly capture the great diversity of the financial instruments available, and hybrid instruments incorporate elements of both equity and debt. From a tax perspective, the classification of hybrid instruments as equity or debt is crucial. This article examines the circumstances in which the yield of a hybrid financial instrument can or must be qualified as either a dividend or interest under tax treaties irrespective of the treatment under the domestic laws of the contracting states.

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    8
    popularity
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    Average
    influence
    This indicator reflects the overall/total impact of an article in the research community at large, based on the underlying citation network (diachronically).
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    impulse
    This indicator reflects the initial momentum of an article directly after its publication, based on the underlying citation network.
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Powered by OpenAIRE graph
Found an issue? Give us feedback
selected citations
These citations are derived from selected sources.
This is an alternative to the "Influence" indicator, which also reflects the overall/total impact of an article in the research community at large, based on the underlying citation network (diachronically).
BIP!Citations provided by BIP!
popularity
This indicator reflects the "current" impact/attention (the "hype") of an article in the research community at large, based on the underlying citation network.
BIP!Popularity provided by BIP!
influence
This indicator reflects the overall/total impact of an article in the research community at large, based on the underlying citation network (diachronically).
BIP!Influence provided by BIP!
impulse
This indicator reflects the initial momentum of an article directly after its publication, based on the underlying citation network.
BIP!Impulse provided by BIP!
8
Average
Top 10%
Average
Related to Research communities
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