The Resource A conundrum within the conundrum : the requalification of loans as equity under the OECD guidance on financial transactions

A conundrum within the conundrum : the requalification of loans as equity under the OECD guidance on financial transactions

Label
A conundrum within the conundrum : the requalification of loans as equity under the OECD guidance on financial transactions
Title
A conundrum within the conundrum : the requalification of loans as equity under the OECD guidance on financial transactions
Creator
Subject
Language
eng
Summary
In this article, the authors raise questions regarding the applicability of the recent OECD Guidance on Financial Transactions to the requalification of debt instruments as equity. The authors demonstrate that the current guidance is potentially inapplicable in many EU Member States and, perhaps, even in most OECD jurisdictions. Moreover, even where applied, such requalification might result in mismatches. Although Italy is taken as the example, the question addressed potentially involves a number of jurisdictions
Citation source
In: European taxation. - Amsterdam. - Vol. 60 (2020), no. 8 ; p. 357-364
http://library.link/vocab/creatorName
  • Piran, G
  • Piva, M
Geographic coverage
  • International
  • European Union
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • debt capital
  • equity capital
  • income classification
  • transfer pricing adjustment
  • fundamental freedoms
  • ECJ case law
Label
A conundrum within the conundrum : the requalification of loans as equity under the OECD guidance on financial transactions
Instantiates
Publication
Label
A conundrum within the conundrum : the requalification of loans as equity under the OECD guidance on financial transactions
Publication

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