目次

PART I Setting the Scene 1 Introduction 2 Non-tax Framework and Drivers 3 Basic Principles Determining the Taxation of Debt, Equity and Hybrid Financial Instruments PART II General Tax Framework Applicable to the Classification of Hybrid Financial Instruments 4 Domestic Criteria Applied to the Classification of Hybrid Financial Instruments 5 Classification of Hybrid Financial Instruments According to Tax Treaties 6 General Principles for the Classification and Taxation of Hybrid Financial Instruments Derived from European Union Law 7 Cross-Border Tax Arbitrage and Hybrid Financial Instruments PART III Classification and Treatment of Specific Hybrid Financial Instruments 8 General Considerations 9 Equity-Flavored Debt Instruments 10 Debt-Flavored Equity Instruments PART IV Conclusions and Tax Policy Recommendations 11 Conclusions 12 Tax Policy Considerations