Taxation Of Corporate Debt And Financial Instruments
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Taxation Of Corporate Debt And Financial Instruments
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Author : David Southern
language : en
Publisher:
Release Date : 2001-12-30
Taxation Of Corporate Debt And Financial Instruments written by David Southern and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2001-12-30 with categories.
This title focuses on the practical implications of the provisions on corporate debt, financial instruments and foreign exchange gains and losses. It covers the interaction between the taxes, the accounting framework, corporate transactions and planning issues. It is a comprehensive and practical guide to the corporate and government debt rules, to the tax and accounting treatment of all instruments used in providing corporate finance, and the treatment of foreign exchange gains and losses arising from such financial transactions. Worked examples throughout illustrate complex points, and it is fully cross-referenced to the legislation and Inland Revenue pronouncements. Changes in practice and legislation up to and including the Finance Act 2001 are included.
Tolley S Taxation Of Corporate Debt And Financial Instruments
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Author : David Southern
language : en
Publisher: Tolley
Release Date : 1998
Tolley S Taxation Of Corporate Debt And Financial Instruments written by David Southern and has been published by Tolley this book supported file pdf, txt, epub, kindle and other format this book has been release on 1998 with Bankruptcy categories.
This work draws together the taxation issues relating to debt instruments used in corporate finance and investment, and offers a complete guide through the maze of new legislation. It focuses on the practical implications of the Finance Act 1996 and also covers the interaction between taxes, the accounting framework, corporate transactions and planning issues.
Taxation Of Corporate Debt And Derivatives
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Author : Julian Ghosh
language : en
Publisher:
Release Date : 2009-04-14
Taxation Of Corporate Debt And Derivatives written by Julian Ghosh and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2009-04-14 with categories.
Offering invaluable tax planning help for the tax specialist, Taxation of Corporate Debt and Derivatives is a highly practical publication, ideal for the busy tax practitioner and lawyer. Debt and Treasury management occupies an increasing proportion of the work of tax practitioners. With considerable legislation to get to grips with, this publication, updated twice per annum, offers a concise and comprehensive version of the law in this area. This publication examines, in detail, each of the regimes involving: * Foreign exchange transactions * Financial instruments (such as options, debt contracts, currency swaps) * Corporate debt, i.e. the loan relationship provisions * Anti-avoidance provisions including thin capitalisation, funding bonds etc
Tolley S Taxation Of Corporate Debt Foreign Exchange And Derivative Contracts
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Author : David Southern
language : en
Publisher:
Release Date : 2002
Tolley S Taxation Of Corporate Debt Foreign Exchange And Derivative Contracts written by David Southern and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2002 with Contracts categories.
A new regime for monetary transactions was heralded by the three separate tax codes introduced from 1993 to 1996 for foreign exchange, financial instruments and loan relationships. Now the proposals for the Finance Act 2002 radically consolidates, extends and recasts the new rules and new anti-avoidance provisions have already taken effect from 26 July 2001.
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.
The Tax Elasticity Of Corporate Debt
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Author : Ruud A. de Mooij
language : en
Publisher: International Monetary Fund
Release Date : 2011-04-01
The Tax Elasticity Of Corporate Debt written by Ruud A. de Mooij and has been published by International Monetary Fund this book supported file pdf, txt, epub, kindle and other format this book has been release on 2011-04-01 with Business & Economics categories.
Although the empirical literature has long struggled to identify the impact of taxes on corporate financial structure, a recent boom in studies offers ample support for the debt bias of taxation. Yet, studies differ considerably in effect size and reveal an equally large variety in methodologies and specifications. This paper sheds light on this variation and assesses the systematic impact on the size of the effects. We find that, typically, a one percentage point higher tax rate increases the debt-asset ratio by between 0.17 and 0.28. Responses are increasing over time, which suggests that debt bias distortions have become more important.
Debt Taxes And Corporate Restructuring
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Author : John B. Shoven
language : en
Publisher: Brookings Institution Press
Release Date : 2012-01-01
Debt Taxes And Corporate Restructuring written by John B. Shoven 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 2012-01-01 with Business & Economics categories.
The boom in corporate restructuring, accompanied by large increases in debt finance, was one of the most important developments in the U.S. economy in the 1980s. Financial and tax specialists analyze how the U.S. tax system-especially in its bias toward debt financing-has affected corporate financial decisions and influenced the recent wave of corporate restructuring. The authors evaluate the hypothesis that the rise in the cost of capital during the 1980s helped stimulate the surge in corporate takeovers. They analyze the effect that changes in tax laws and in the volume of government debt have had on corporate financial decisions. The authors examine how recent financial innovations have blurred the distinction between debt and equity finance.
Ghosh Johnson And Miller On The Taxation Of Corporate Debt And Derivatives
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Author : Julian Ghosh
language : en
Publisher:
Release Date : 2009
Ghosh Johnson And Miller On The Taxation Of Corporate Debt And Derivatives written by Julian Ghosh and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2009 with Corporate debt categories.
Taxation Of Loan Relationships And Derivative Contracts
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Author : David Southern
language : en
Publisher: A&C Black
Release Date : 2012-06-01
Taxation Of Loan Relationships And Derivative Contracts written by David Southern and has been published by A&C Black this book supported file pdf, txt, epub, kindle and other format this book has been release on 2012-06-01 with Business & Economics categories.
The ninth edition of this well-established work offers comprehensive coverage of all aspect of the taxation of loan relationships and derivative contracts in the UK. It covers the UK's IAS 32/39 and FRS 25/26, loan relationships under IAS, impairment losses and connected company rules, the derivative contracts rules, bifurcation of convertibles, transfer pricing domestic and international, the disregard rules on tax hedging, matching and functional currencies, reconstructions and mergers, repos and stock lending, anti-avoidance rules, corporate debt, loan relationships, derivative contracts, securities taxation, and debt impairment. Particular emphasis is placed on providing worked examples and planning guidance.
Hybrid Financial Instruments Double Non Taxation And Linking Rules
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Author : Félix Daniel Martínez Laguna
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2019-06-12
Hybrid Financial Instruments Double Non Taxation And Linking Rules written by Félix Daniel Martínez Laguna 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 2019-06-12 with Law categories.
Hybrid Financial Instruments, Double Non-taxation and Linking Rules Félix Daniel Martínez Laguna Hybrid financial instruments (HFIs) are widespread ordinary financial instruments that combine debt and equity features in their terms and design and may lead to double non-taxation across borders. This important book provides a deeply informed and critical analysis and guide to the “linking rules” developed to combat double non-taxation stemming from HFIs within the framework of the Base Erosion and Profit Shifting project of the Organisation for Economic Co-operation and Development (OECD) and the anti-avoidance initiatives of the European Union (EU). These complex rules have now become essential in international taxation. The book deals incisively with crucial theoretical and practical issues as the following: Economic and legal reasons for financing business activity through debt instruments, equity instruments and/or HFIs. Qualification of financial instruments from different perspectives such as economics, corporate finance, corporate law, financial accounting law, regulatory law and tax law and their interrelation. The concept of double non-taxation as a mere outcome of parallel exercises of sovereignty by different states and the role it plays within the international debate. The concepts of tax planning, tax avoidance and the misleading concept of aggressive tax planning within a tax competition international scenario and their relation with HFIs. Comprehensive policy, legal and technical detail and explanation of the linking rules proposed by the OECD (i.e., BEPS Project Action 2) and the EU (e.g., Anti-Tax Avoidance Directive). The (in)compatibility of linking rules with existing tax treaty rules and EU primary law. The author refers throughout to relevant model convention provisions, EU case law and a vast number of references of official documentation and literature. With its detailed attention to the concept and legal nature of HFIs and double non-taxation, the critical and comprehensive analysis of the linking rules developed by the OECD and the EU, this provocative book allows to reconsider the legality of these linking rules and will quickly become a much-used problem-solving resource for policymakers, tax practitioners, tax authorities and tax academics. This book allows to rethink whether linking rules relate to a solution or create actual legal issues.