The Resource The impact of the new general anti-avoidance rules on the assessment of hybrid financial instruments and entities

The impact of the new general anti-avoidance rules on the assessment of hybrid financial instruments and entities

Label
The impact of the new general anti-avoidance rules on the assessment of hybrid financial instruments and entities
Title
The impact of the new general anti-avoidance rules on the assessment of hybrid financial instruments and entities
Creator
Subject
Language
eng
Summary
Hybrid financial instruments and entities lack any express regulation within Chilean tax law. This legal void, alongside the highly formalistic interpretation of the law applied by the Chilean tax authorities, has led to a rejection of transparent entities for Chilean tax purposes, and a classification of hybrid financial instruments as "debt" or "equity" based solely on formal arguments. New general anti-avoidance rules (2014) have introduced a substance-over-form principle, which is starting to be factually and preventively applied by the Chilean tax authorities. This analysis aims to illustrate the above-mentioned trend, in particular as it relates to hybrid financial instruments and entities, traditionally "no man's land" for tax purposes
Citation source
In: Derivatives and financial instruments. - Amsterdam. - Vol. 21 (2019), no. 5 ; 7 p
http://library.link/vocab/creatorName
  • Czollak, A
  • Yáñez Villanueva, F
Geographic coverage
  • South America
  • Latin America
Language note
English
http://library.link/vocab/subjectName
  • GAAR
  • hybrid financial instrument
  • hybrid entity
  • entity classification
  • equity capital
  • debt capital
  • ruling
Label
The impact of the new general anti-avoidance rules on the assessment of hybrid financial instruments and entities
Instantiates
Publication
Label
The impact of the new general anti-avoidance rules on the assessment of hybrid financial instruments and entities
Publication

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      52.3736660 4.9336932
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