Tax Arbitrage
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Tax Arbitrage
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Author : Nigel Feetham
language : en
Publisher: Spiramus Press Ltd
Release Date : 2011
Tax Arbitrage written by Nigel Feetham and has been published by Spiramus Press Ltd this book supported file pdf, txt, epub, kindle and other format this book has been release on 2011 with Business & Economics categories.
Press coverage has often shown little understanding of the distinction between tax avoidance and tax evasion, describing the legitimate behaviour of taxpayer banks, financial institutions and multinational businesses in emotive terms and often inaccurately. This book aims to look at tax arbitrage, and demystify its practice.
Tax Arbitrage And The Changing Structure Of International Tax Law
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Author : Luca Dell'Anese
language : en
Publisher:
Release Date : 2006
Tax Arbitrage And The Changing Structure Of International Tax Law written by Luca Dell'Anese and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2006 with Business & Economics categories.
Tax Arbitrage Through Cross Border Financial Engineering
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Author : Gaspar Lopes Dias V.S.
language : en
Publisher: Kluwer Law International
Release Date : 2015
Tax Arbitrage Through Cross Border Financial Engineering written by Gaspar Lopes Dias V.S. and has been published by Kluwer Law International this book supported file pdf, txt, epub, kindle and other format this book has been release on 2015 with Law categories.
This book explores tax arbitrage opportunities resulting from financial engineering techniques with cross-border financial instruments such as hybrids, synthetics, and non-traditional financial instruments. Firstly the author clarifies the concept of three kinds of complex financial instruments, and thereafter he discusses the most adequate tax treatment of these instruments in cross-border situations. For this purpose he identifies economic substance as an objective benchmark for the taxation of financial instruments to achieve greater international tax neutrality, and examines the role of the expected return taxation theory. The book also contains a comparative analysis of relevant developments in a number of jurisdictions, including Australia, Belgium, Brazil, Luxembourg, Portugal, UK and USA.
Addressing Tax Arbitrage With Hybrid Financial Instruments
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Author : Moritz Scherleitner
language : en
Publisher:
Release Date : 2020
Addressing Tax Arbitrage With Hybrid Financial Instruments written by Moritz Scherleitner and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2020 with categories.
Tax Arbitrage In The Netherlands
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Author : Bert Johan Brys
language : en
Publisher: Rozenberg Publishers
Release Date : 2005
Tax Arbitrage In The Netherlands written by Bert Johan Brys and has been published by Rozenberg Publishers this book supported file pdf, txt, epub, kindle and other format this book has been release on 2005 with Capital levy categories.
Abcs Of Arbitrage
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Author : Frederic L. Ballard
language : en
Publisher: American Bar Association
Release Date : 2007
Abcs Of Arbitrage written by Frederic L. Ballard and has been published by American Bar Association this book supported file pdf, txt, epub, kindle and other format this book has been release on 2007 with Business & Economics categories.
Hybrid Financial Instruments In International Tax Law
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Author : Jakob Bundgaard
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2016-11-15
Hybrid Financial Instruments In International Tax Law written by Jakob Bundgaard and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2016-11-15 with Law categories.
Financial innovation allows companies and other entities that wish to raise capital to choose from a myriad of possible instruments that can be tailored to meet the specific business needs of the issuer and investor. However, such instruments put increasing pressure on a question that is fundamental to the tax and financial systems of a country – the distinction between debt and equity. Focusing on hybrid financial instruments (HFIs) – which lie somewhere along the debt-equity continuum, but where exactly depends on the terms of the instrument as well as on applicable laws – this book analyses their treatment under both domestic law and tax treaties. Key jurisdictions, including the EU, some of its Member States, and the United States, are covered. Advocating for a broader scope of application of HFIs as part of the financing of companies in Europe alongside traditional sources of debt and equity financing, the book addresses such issues and topics as the following: • problems associated with the debt-equity distinction in international tax law; • cross-border tax arbitrage and linking rules; • drivers behind the use and design of HFIs; • tax law impact of perpetual and super maturity debt instruments, profit participating loans, convertible bonds, mandatory convertible bonds, contingent convertibles, preference shares and warrant loans on HFIs; • financial accounting treatment; • administrative guidance; • influence of the TFEU on Member States’ approaches to classification of HFIs; • interpretation of the Parent-Subsidiary Directive by the European Court of Justice; • applicability of the OECD Model Tax Convention; and • implications of the OECD Base Erosion and Profit Shifting (BEPS) project. Throughout this book, the analysis draws upon preparatory works, case law, and legal theory in English, German, and the Scandinavian languages. In conclusion, the author considers tax policy issues, and identifies and outlines possible high-level solutions. Actual or potential users of HFIs will greatly appreciate the clarity and insight offered here into the capacity and tax implications of HFIs. The book not only examines whether existing legislation is sufficient to handle the issues raised by international HFIs, but also provides an in-depth analysis of the interaction between corporate financing and tax law in the light of today’s financial innovation. Corporate executives and their counsel will find it indispensable in the international taxation landscape that is currently coming into view, and academics and policymakers will hugely augment their understanding of a complex and constantly changing area of tax law.
Taxation Of Derivatives
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Author : Oktavia Weidmann
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2015-07-16
Taxation Of Derivatives written by Oktavia Weidmann and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2015-07-16 with Law categories.
The exploding use of derivatives in the last two decades 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 very thorough 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 greatly 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. By providing an in-depth analysis of corporate taxation issues that arise in domestic as well as in cross-border derivatives transactions, this book is not only timely but of lasting value in the day-to-day work of tax lawyers and tax professionals in companies, banks and funds, and is sure to be of interest to government officials, academics and researchers involved with financial instruments taxation.
The Dilemma Of International Tax Arbitrage
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Author : Shay Nisan Menuchin
language : en
Publisher:
Release Date : 2005
The Dilemma Of International Tax Arbitrage written by Shay Nisan Menuchin and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2005 with categories.
Taxes Loans And Inflation
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Author : C. Eugene Steuerle
language : en
Publisher: Brookings Institution Press
Release Date : 2010-12-01
Taxes Loans And Inflation written by C. Eugene Steuerle and has been published by Brookings Institution Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2010-12-01 with Business & Economics categories.
Income from capital receives uneven treatment in both the tax system and the loan markets. This affects almost every investment decision make by the individuals, business, and government and causes major disruptions in the economy. In this book C. Eugene Steuerle shows how the misallocation of capital results from the interaction of tax laws, the operation of the market for loanable funds, and inflation. He first analyzes the taxation of capital income, focusing on the distortions caused by tax arbitrage and on inflation-induced discriminations among both taxpayer and borrowers. The author then applies this analysis to several related issues. He concludes with a reform agenda that calls for the adoption of a broader-based, flatter-rate income tax.