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The Resource Taxation of derivatives

Taxation of derivatives

Label
Taxation of derivatives
Title
Taxation of derivatives
Creator
Subject
Language
eng
Summary
The exploding use of derivatives since the turn of the century has created a major challenge for tax authorities, who had to develop appropriate derivatives taxation rules that strike a balance between allowing capital markets to function effectively by removing artificial tax barriers and at the same time protecting their countries' tax base from tax avoidance schemes that utilise these instruments. Derivatives exist in a vast variety and complexity and new forms or combinations of existing forms appear ad hoc as new risk categories emerge and companies seek to invest in or hedge these risks. This book discusses and analyses taxation issues posed by derivatives used in domestic as well as in cross-border transactions. In great detail the author presents approaches that can be adopted by tax legislators to solve these problems, clarifying her solutions with specific reference to components of the two most important domestic tax systems in relation to derivatives in Europe, those of the United Kingdom and Germany. Examples of derivatives transactions and arbitrage schemes elucidate the nature of derivatives and how they can be effectively taxed. The following aspects of the subject and more are covered: - basic economic concepts in the context of derivatives such as replication, put-call-parity, hedging and leverage; - designing a suitable definition of derivatives in domestic tax law; - achieving coherence in domestic tax rules by applying a 'special regime approach' versus an 'integrative approach' and the distinction of income and capital, equity and debt; - alignment of accounting standards and taxation rules and the application of fair value accounting for tax purposes; - how to tax hedged positions and post-tax hedging schemes; - taxation of structured financial products and hybrid instruments with focus on bifurcation and integration approaches and the recent BEPS discussion drafts on hybrid mismatch arrangements; - refining the 'beneficial ownership' concept in domestic law and in tax treaties and an analysis of recent case law; - withholding taxes in the context of domestic and cross-border dividend tax arbitrage schemes; and, - tackling derivatives tax arbitrage effectively in anti-avoidance legislation
http://library.link/vocab/creatorName
Weidmann, O
Geographic coverage
International
Index
no index present
Language note
English
Literary form
non fiction
Series statement
Series on international taxation
Series volume
52
http://library.link/vocab/subjectName
  • derivative financial instrument
  • accounting
  • hedging transaction
  • beneficial ownership
  • tax arbitrage
  • GAAR
  • dividend stripping
Label
Taxation of derivatives
Instantiates
Publication
Extent
xxviii, 408 p.
Isbn
9789041159779
Label
Taxation of derivatives
Publication
Extent
xxviii, 408 p.
Isbn
9789041159779

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.37366609999999 4.9336932
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