The Resource Tax avoidance with hybrid financial instruments among European countries

Tax avoidance with hybrid financial instruments among European countries

Label
Tax avoidance with hybrid financial instruments among European countries
Title
Tax avoidance with hybrid financial instruments among European countries
Creator
Subject
Language
eng
Summary
Multinational companies can use hybrid financial instruments (HFIs) to reduce their tax burden. To achieve such a reduction corporations can exploit the differences that exist between countries in respect of their national tax laws. By evaluating the rules governing separation between equity and debt in Germany, France, the UK, the Netherlands, and Luxembourg, this article finds that there are various qualification conflicts which give rise to tax avoidance opportunities in these countries. The implementation of linking rules, a central anti-avoidance mechanism recommended by the OECD, has reduced the revealed tax avoidance opportunities over time. Considering ATAD I and ATAD II, this article analyses former, current, and future tax avoidance opportunities resulting from the use of HFIs
Citation source
In: British tax review. - London. - (2020), no. 2 ; p. 217-240
http://library.link/vocab/creatorName
Holtmann, S
Geographic coverage
  • Europe
  • European Union
Language note
English
http://library.link/vocab/subjectName
  • tax avoidance
  • hybrid financial instrument
  • hybrid mismatch
  • equity capital
  • debt
  • linking rules
  • anti-avoidance
  • MNE
  • ATAD
  • ATAD 2
  • securities
Label
Tax avoidance with hybrid financial instruments among European countries
Instantiates
Publication
Label
Tax avoidance with hybrid financial instruments among European countries
Publication

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