The Resource Cross-border tax arbitrage using inbound hybrid financial instruments curbed in Denmark by unilateral reclassification of debt into equity

Cross-border tax arbitrage using inbound hybrid financial instruments curbed in Denmark by unilateral reclassification of debt into equity

Label
Cross-border tax arbitrage using inbound hybrid financial instruments curbed in Denmark by unilateral reclassification of debt into equity
Title
Cross-border tax arbitrage using inbound hybrid financial instruments curbed in Denmark by unilateral reclassification of debt into equity
Creator
Subject
Language
eng
Summary
This article analyses a new provision in Danish tax law - Sec. 2B of the Corporation Tax Act - aimed at curbing cross-border tax arbitrage through the use of hybrid financial instruments. The effect of the provision is to reclassify debt between group companies as equity, and thus interest into dividends. The article examines the requirements for applying Sec. 2B and provides a comprehensive analysis of the consequences of doing so
Citation source
In: Bulletin for international taxation. - Amsterdam. - Vol. 62 (2008),
http://library.link/vocab/creatorName
Bundgaard, J
Geographic coverage
European Union
Language note
English
http://library.link/vocab/subjectName
  • hybrid financial instrument
  • tax arbitrage
  • tax policy
Label
Cross-border tax arbitrage using inbound hybrid financial instruments curbed in Denmark by unilateral reclassification of debt into equity
Instantiates
Publication
Label
Cross-border tax arbitrage using inbound hybrid financial instruments curbed in Denmark by unilateral reclassification of debt into equity
Publication

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