A service provided by the WU Library and the WU IT-Services

The Consequences of Hybrid Finance in Thin Capitalization Situations. An Analysis of the Substantive Scope of National Thin Capitalization Rules with special Emphasis on Hybrid Financial Instruments.

Klostermann, Margret (2007) The Consequences of Hybrid Finance in Thin Capitalization Situations. An Analysis of the Substantive Scope of National Thin Capitalization Rules with special Emphasis on Hybrid Financial Instruments. Discussion Papers SFB International Tax Coordination, 22. SFB International Tax Coordination, WU Vienna University of Economics and Business, Vienna.

[img]
Preview
PDF
Download (393Kb) | Preview

Abstract

The choice of corporate finance is an important source of tax planning opportunities for multinational companies. Investing companies have to be aware of inconsistent tax classification of equity and debt between countries in particular. Additionally, thin capitalization rules have to be taken into account. In response to changing corporate needs the present paper focuses on the tax consequences of hybrid financial instruments. Only some literature exists on cross-border hybrid finance. Especially the linkage between the two areas - hybrid finance and thin capitalization - both on a national and international level had to be dealt with academically. The paper analyses the substantive scope of thin capitalization regimes in general and in detail. The main finding is that the tax consequences of hybrid instruments reverse when used in thin capitalization situations and that traditional tax policy has to be reconsidered. (author's abstract)

Item Type: Paper
Keywords: corporate finance / hybrid financial instruments / thin capitalization rules / corporate taxation
Classification Codes: RVK QL 530
Divisions: Departments > Finance, Accounting and Statistics > Accounting and Auditing > Betriebswirtschaftliche Steuerlehre
Departments > Volkswirtschaft
Departments > Öffentliches Recht und Steuerrecht > Österr. und Internat. Steuerrecht
Depositing User: Repository Administrator
Date Deposited: 02 Jul 2007 13:43
Last Modified: 21 Nov 2014 09:03
URI: http://epub.wu.ac.at/id/eprint/398

Actions

View Item