Download or read book Hybrid Financial Instruments in International Tax Law written by Jakob Bundgaard and published by Kluwer Law International B.V.. This book was released on 2016-11-15 with total page 408 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Download or read book Fiches de Droit des instruments de paiement et de cr dit written by Marianne Villemonteix and published by . This book was released on 2024-09-17 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Fiches de droit des instruments de paiement et de cr dit written by Marianne Lecene-Villemonteix and published by . This book was released on 2013 with total page 185 pages. Available in PDF, EPUB and Kindle. Book excerpt: La 4e de couverture indique : "Cet ouvrage contient : 23 fiches de cours pour réviser tout le cours de Droit des instruments de paiement et de crédit : les définitions à connaître, les erreurs à éviter, les points essentiels à retenir ; des exercices corrigés pour vérifier ses connaissances : 21 questions de cours, 13 cas pratiques, 2 dissertations, 1 commentaire d'article, 1 exercice de prétoire ; des repères bibliographiques pour aller plus loin ; 1 index."
Download or read book Gone with the Headwinds written by Gustavo Adler and published by International Monetary Fund. This book was released on 2017-04-03 with total page 98 pages. Available in PDF, EPUB and Kindle. Book excerpt: to come
Download or read book Glossary of Finance and Debt written by and published by . This book was released on 1990 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Glosario Del Banco Mundial written by World Bank and published by World Bank Publications. This book was released on 1996 with total page 468 pages. Available in PDF, EPUB and Kindle. Book excerpt: This edition of the World Bank has been revised and expanded by the Terminology Unit in the Languages Services Division of the World Bank in collaboration with the English, Spanish, and French Translation Sections. The Glossary is intended to assist the Bank's translators and interpreters, other Bank staff using French and Spanish in their work, and free-lance translator's and interpreters employed by the Bank. For this reason, the Glossary contains not only financial and economic terminology and terms relating to the Bank's procedures and practices, but also terms that frequently occur in Bank documents, and others for which the Bank has a preferred equivalent. Although many of these terms, relating to such fields as agriculture, education, energy, housing, law, technology, and transportation, could be found in other sources, they have been assembled here for ease of reference. A list of acronyms occurring frequently in Bank texts (the terms to which they refer being found in the Glossary) and a list of international, regional, and national organizations will be found at the end of the Glossary.
Download or read book Fiches de Droit des instruments de paiement et de cr dit written by Marianne Villemonteix and published by Editions Ellipses. This book was released on 2024-09-17 with total page 232 pages. Available in PDF, EPUB and Kindle. Book excerpt: 23 fiches pour réviser tout le cours de Droit des instruments de paiement et de crédit : les définitions à connaître, les erreurs à éviter, les points essentiels à retenir ;des exercices corrigés pour vérifier ses connaissances : questions de cours, dissertations, commentaires d'article et cas pratiques ;des repères bibliographiques pour aller plus loin ;1 index.
Download or read book Murder Manslaughter and Infanticide written by Great Britain: Law Commission and published by The Stationery Office. This book was released on 2006-11-29 with total page 280 pages. Available in PDF, EPUB and Kindle. Book excerpt: A Law Commission consultation paper 'A new homicide act for England and Wales?' was published as LCCP 177 (ISBN 0117302643) in April 2006.
Download or read book French books in print anglais written by Electre and published by . This book was released on 2000 with total page 1844 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Innovate Bristol written by Sven Boermeester and published by . This book was released on 2019-12 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: Innovate Bristol highlights and celebrates those companies and individuals that are actively working at building a better tomorrow for all. Innovation Ecosystems thrive through the involvement and support of companies and individuals from all industries, which is why the Innovate series not only focuses on the innovators but also those people whom the Innovation Ecosystem, would not be able to thrive without.
Download or read book Dictionary of Building and Civil Engineering written by Don Montague and published by Taylor & Francis. This book was released on 1996 with total page 472 pages. Available in PDF, EPUB and Kindle. Book excerpt: This dual-language dictionary lists over 20,000 specialist terms in both French and English, covering architecture, building, engineering and property terms. It meets the needs of all building professionals working on projects overseas. It has been comprehensively researched and compiled to provide an invaluable reference source in an increasingly European marketplace.
Download or read book Crying Out for Change written by Deepa Narayan-Parker and published by World Bank Publications. This book was released on 2000 with total page 342 pages. Available in PDF, EPUB and Kindle. Book excerpt: A multi-country research initiative to understand poverty from the eyes of the poor, the Voices of the Poor project was undertaken to inform the World Bank's activities and the upcoming World Development Report 2000/01. The research findings are being published in three books: "Can Anyone Hear Us?" gathers the voices of over 40,000 poor women and men in 50 countries from the World Bank's participatory poverty assessments (Deepa Narayan, Raj Patel, Kai Schafft, Anne Rademacher, and Sarah Koch-Schulte, authors). "Crying Out for Change" pulls together new field work conducted in 1999 in 23 countries (Deepa Narayan, Robert Chambers, Meera Shah, and Patti Petesch, authors). "From Many Lands" offers regional patterns and country case-studies (Deepa Narayan and Patti Petesch, editors). Voices of the Poor marks the first time such an exercise has been undertaken in so many developing countries and transition economies around the world. It provides a unique and detailed picture of the life of the poor and explains the constraints poor people face to escape from poverty in a way that more traditional survey techniques do not capture well. Each of the three volumes demonstrates the importance of voice and power in poor people's definition of poverty. Voices of the Poor concludes that we need to expand our conventional views of poverty which focus on income expenditure, education, and health to include measures of voice and empowerment.
Download or read book European State Aid Law written by Louis Vogel and published by . This book was released on 2020 with total page 432 pages. Available in PDF, EPUB and Kindle. Book excerpt: European State Aid Law' provides a wide-ranging comparative review of the applicable European rules: prohibited aid, compatible aid, control procedure.00Extensively referencing case law and legislative and regulatory sources, 'European State Aid Law' interprets the various complex rules and illustrates how they may interact and develop.
Download or read book Syst me Canadien de Paiement Et L ordinateur written by Howard R. Eddy and published by . This book was released on 1974 with total page 196 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Handbook of Terminology electronic Resource written by Pavel, Silvia and published by . This book was released on 2002 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Text of the General Agreement written by General Agreement on Tariffs and Trade (Organization) and published by . This book was released on 1986 with total page 108 pages. Available in PDF, EPUB and Kindle. Book excerpt: Internal taxation, anti-dumping, trade regulations, balance of payments, economic development.
