Taxation of Hybrid Financial Instruments and the Remuneration Derived Therefrom in an International and Cross-border Context

Issues and Options for Reform

  • Sven-Eric Bärsch

Table of contents

  1. Front Matter
    Pages i-xxii
  2. Sven-Eric Bärsch
    Pages 1-7
  3. Sven-Eric Bärsch
    Pages 9-41
  4. Sven-Eric Bärsch
    Pages 241-319
  5. Sven-Eric Bärsch
    Pages 321-324
  6. Back Matter
    Pages 325-388

About this book


Despite the enormous diversity and complexity of financial instruments, the current taxation of hybrid financial instruments and the remuneration derived therefrom are characterized by a neat division into dividend-generating equity and interest-generating debt as well as by a coexistence of source- and residence-based taxation. This book provides a comparative analysis of the classification of hybrid financial instruments in the national tax rules currently applied by Australia, Germany, Italy and the Netherlands as well as in the relevant tax treaties and EU Directives. Moreover, based on selected hybrid financial instruments, mismatches in these tax classifications, which lead to tax planning opportunities and risks and thus are in conflict with the single tax principle, are identified. To address these issues, the author provides reform options that are in line with the dichotomous debt-equity framework, as he/she suggests the coordination of either tax classifications or tax treatments


Double Tax Treaties EU Directives Financial Instruments Hybrid International Taxation

Authors and affiliations

  • Sven-Eric Bärsch
    • 1
  1. 1.Business School, Chair of International TaxationUniversity of MannheimMannheimGermany

Bibliographic information

  • DOI
  • Copyright Information Springer-Verlag Berlin Heidelberg 2012
  • Publisher Name Springer, Berlin, Heidelberg
  • eBook Packages Business and Economics
  • Print ISBN 978-3-642-32456-7
  • Online ISBN 978-3-642-32457-4
  • Buy this book on publisher's site