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Hybrid Financial Instrument
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Book Synopsis Hybrid Financial Instruments by : Brian Coyle
Download or read book Hybrid Financial Instruments written by Brian Coyle and published by Global Professional Publishi. This book was released on 2002 with total page 172 pages. Available in PDF, EPUB and Kindle. Book excerpt: From the "Risk Management" series, this is a concise and practical guide to financial instruments that are made up of two or more other instruments. The term "hybrid" has come to cover a wide range of financial products and this book seeks to explain the more commonly used ones. They are examined from the perspective of both ......
Book Synopsis Hybrid Financial Instruments by : Tony Rice
Download or read book Hybrid Financial Instruments written by Tony Rice and published by . This book was released on 1993 with total page 120 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Hybrid Financial Instruments in International Tax Law by : Jakob Bundgaard
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 498 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.
Book Synopsis Hybrid Securities by : Kamil Liberadzki
Download or read book Hybrid Securities written by Kamil Liberadzki and published by Springer. This book was released on 2016-04-08 with total page 228 pages. Available in PDF, EPUB and Kindle. Book excerpt: Hybrid capital securities or 'hybrids' offer various benefits. They offer flexibility equity without shareholder dilution, provide protection to senior creditors, are a stable source of long-term funding for healthy companies, and help insurers and banks meet regulatory and rating agency capital requirements. Risks and features of hybrid securities are expressed in the credit spread of some relatively new financial instruments, but no structural fundamentals exist for to price hybrids precisely. This book proposes a model for the pricing of hybrids. It begins by explaining the concept of hybrids as well as their equity- and debt-like characteristics. Different types of hybrids are presented, including preference shares, convertible bonds, contingent convertibles (CoCos) and bail-in bonds. The authors then present analysis of regulatory regimes' impact on hybrids. They discuss the types of hybrid bonds that are contemplated in the Capital Requirements Regulation (CRR) and Banking Union mechanism. They then present an in-depth examination of hybrids pricing and risk assessment techniques. The book provides a comprehensive analysis from mathematical, legal and financial perspectives in order to look at relatively new financial instruments and address problems with the pricing models of hybrids which are as yet unsolved.
Book Synopsis How Do Experienced Users Evaluate Hybrid Financial Instruments? by : Shana Clor-Proell
Download or read book How Do Experienced Users Evaluate Hybrid Financial Instruments? written by Shana Clor-Proell and published by . This book was released on 2016 with total page 44 pages. Available in PDF, EPUB and Kindle. Book excerpt: Hybrid financial instruments contain features of both liabilities and equity. Standard setters continue to struggle with “getting the classification right” for these complex instruments. In this paper, we experimentally test whether the features of hybrid instruments affect the credit-related judgments of experienced finance professionals, even when the hybrid instruments are already classified as liabilities or equity. Our results suggest that getting the classification right is not of primary importance for these experienced users, as they largely rely on the underlying features of the instrument to make their judgments. A second experiment shows that experienced users' reliance on features generalizes to several features that often characterize hybrid instruments. However, we also find that experienced users vary in their beliefs about which individual features are most important in distinguishing between liabilities and equity. Together, our results highlight the importance of effective disclosure of hybrid instruments' features.
Book Synopsis The Hybrid Financial Instruments : the Effects of the OECD BEPS Action 2 Report and the ATAD. by : Bart Peeters
Download or read book The Hybrid Financial Instruments : the Effects of the OECD BEPS Action 2 Report and the ATAD. written by Bart Peeters and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This contribution provides a critical comprehensive analysis of the complex hybrid mismatches rules concerning financial instruments. Challenging the compatibility of ATAD with the OECD initiative, the authors illuminate the differences between both approaches and identify risks of conflicting domestic implementations caused by remaining uncertainties of this hybrid financial instrument rule. As EU-Member States had to transpose the provisions of the hybrid financial instrument rule by 31 December 2019 and apply them per 1 January 2020, 2019 was the year that domestic legislators had to confront existing domestic rules with these requirements.
Book Synopsis Taxation of Hybrid Financial Instruments and the Remuneration Derived Therefrom in an International and Cross-border Context by : Sven-Eric Bärsch
Download or read book Taxation of Hybrid Financial Instruments and the Remuneration Derived Therefrom in an International and Cross-border Context written by Sven-Eric Bärsch and published by Springer Science & Business Media. This book was released on 2012-12-13 with total page 406 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Book Synopsis Capital Structure and Corporate Governance by : Lorenzo Sasso
Download or read book Capital Structure and Corporate Governance written by Lorenzo Sasso and published by Kluwer Law International B.V.. This book was released on 2013-08-01 with total page 248 pages. Available in PDF, EPUB and Kindle. Book excerpt: Despite a clear distinction in law between equity and debt, the results of such a categorization can be misleading. The growth of financial innovation in recent decades necessitates the allocation of control and cash-flow rights in a way that diverges from the classic understanding. Some of the financial instruments issued by companies, so-called hybrid instruments, fall into a grey area between debt and equity, forcing regulators to look beyond the legal form of an instrument to its practical substance. This innovative study, by emphasizing the agency relations and the property law claims embedded in the use of such unconventional instruments, analyses and discusses the governance regulation of hybrids in a way that is primarily functional, departing from more common approaches that focus on tax advantages and internal corporate control. The author assesses the role of hybrid instruments in the modern company, unveiling the costs and benefits of issuing these securities, recognizing and categorizing the different problem fields in which hybrids play an important role, and identifying legal and contracting solutions to governance and finance problems. The full-scale analysis compares the U.K. law dealing with hybrid instruments with the corresponding law of the most relevant U.S. jurisdictions in relation to company law. The following issues, among many others, are raised: decisions under uncertainty when the risks of opportunism of the parties is very high; contract incompleteness and ex post conflicts; protection of convertible bondholders in mergers and acquisitions and in assets disposal; use of convertible bonds to reorganise and restructure a firm; timing of the conversion and the issuer’s call option; majority-minority conflict in venture capital financing; duty of loyalty; fiduciary duties to preference shareholders; and financial contract design for controlling the board’s power in exit events. Throughout, the analysis includes discussion, comparison, and evaluation of statutory provisions, existing legal standards, and strategies for protection. It is unlikely that a more thorough or informative account exists of the complex regulatory problems created by hybrid financial instruments and of the different ways in which regulatory regimes have responded to the problems they raise. Because business parties in these jurisdictions have a lot of scope and a strong incentive to contract for their rights, this book will also be of uncommon practical value to corporate counsel and financial regulators as well as to interested academics.
Book Synopsis Hybrid Financial Instrument by : Indrajit Dube
Download or read book Hybrid Financial Instrument written by Indrajit Dube and published by . This book was released on 2019 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: In cross-border transactions, the companies try to take advantage of the difference in tax policies of various jurisdictions with the use of hybrid instruments which take into account share ownership, capital markets, and business culture. The instruments are designed in such a way that they are treated as debt in one jurisdiction and as equity in the other to take advantages of both the categories. This article takes three parameters, i.e. tax, corporate governance and future access to capital in the design of the hybrid financial instrument.
Book Synopsis Hybrid Financial Instruments in International Tax Law by : Jakob Bundgaard
Download or read book Hybrid Financial Instruments in International Tax Law written by Jakob Bundgaard and published by . This book was released on with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis The Handbook of Hybrid Securities by : Jan De Spiegeleer
Download or read book The Handbook of Hybrid Securities written by Jan De Spiegeleer and published by John Wiley & Sons. This book was released on 2014-05-19 with total page 421 pages. Available in PDF, EPUB and Kindle. Book excerpt: Introducing a revolutionary new quantitative approach to hybrid securities valuation and risk management To an equity trader they are shares. For the trader at the fixed income desk, they are bonds (after all, they pay coupons, so what's the problem?). They are hybrid securities. Neither equity nor debt, they possess characteristics of both, and carry unique risks that cannot be ignored, but are often woefully misunderstood. The first and only book of its kind, The Handbook of Hybrid Securities dispels the many myths and misconceptions about hybrid securities and arms you with a quantitative, practical approach to dealing with them from a valuation and risk management point of view. Describes a unique, quantitative approach to hybrid valuation and risk management that uses new structural and multi-factor models Provides strategies for the full range of hybrid asset classes, including convertible bonds, preferreds, trust preferreds, contingent convertibles, bonds labeled "additional Tier 1," and more Offers an expert review of current regulatory climate regarding hybrids, globally, and explores likely political developments and their potential impact on the hybrid market The most up-to-date, in-depth book on the subject, this is a valuable working resource for traders, analysts and risk managers, and a indispensable reference for regulators
Book Synopsis Addressing Tax Arbitrage with Hybrid Financial Instruments by : Moritz Scherleitner
Download or read book Addressing Tax Arbitrage with Hybrid Financial Instruments written by Moritz Scherleitner and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Hybrid finance in the double tax treaties by : Martin Alexander Six
Download or read book Hybrid finance in the double tax treaties written by Martin Alexander Six and published by . This book was released on 2007 with total page 13 pages. Available in PDF, EPUB and Kindle. Book excerpt: The compartmentalisation of company finance into equity and debt does not truly capture the enormous diversity of financial instruments available. A wide variety of hybrid instruments incorporate elements of both equity and debt. From a fiscal point of view the classification of such hybrid instruments as equity or debt is crucial for two reasons. First of all, the issuer can treat interest on the latter as tax-deductible in most cases, and secondly, for the investor the classification determines whether the payments received from the respective instrument is treated as a dividend or as interest. One important question in this context is how hybrid instruments are treated in the tax treaty between the source state and the residence state. It is the aim of this paper, to show how the yield on hybrid financial instruments can or must be qualified as either dividend or interest in the double tax treaties, irrespective of the treatment in contracting states. (author's abstract).
Book Synopsis Institutional Hybrid Financial Instruments and Double Non-taxation Under Domestic Rules and Tax Treaty Law : the Example of Spain by : F.D. Martínez Laguna
Download or read book Institutional Hybrid Financial Instruments and Double Non-taxation Under Domestic Rules and Tax Treaty Law : the Example of Spain written by F.D. Martínez Laguna and published by . This book was released on 2016 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: Attention has been paid to double non-taxation resulting from contractual hybrid financial instruments, which are instruments that share debt and equity features. This article focuses on a specific Institutional Hybrid Financial Instrument instead. Institutional Hybrid Financial Instruments are equity instruments that could equally lead to conflicts of qualification and double non-taxation considering the deductibility from a tax perspective according to a tax policy decision. The analysis deals with the application of the Spanish exemption method to Brazilian Juros sobre o Capital Próprio from a domestic law and tax treaty perspective. Moreover, the implementation of linking rules and its implications regarding hybrid financial instruments are also considered.
Book Synopsis Statement of Financial Accounting Standards No. 155 by : Financial Accounting Standards Board
Download or read book Statement of Financial Accounting Standards No. 155 written by Financial Accounting Standards Board and published by . This book was released on 2006 with total page 46 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Qualification of Hybrid Financial Instruments in Tax Treaties by : Francisco Alfredo Garcia Prats
Download or read book Qualification of Hybrid Financial Instruments in Tax Treaties written by Francisco Alfredo Garcia Prats and published by . This book was released on 2013 with total page 32 pages. Available in PDF, EPUB and Kindle. Book excerpt: The article deals with the interesting issue of the tax treaty qualification problems arising in hybrid financial instruments and structures. The need to fit the great diversity of instruments and legal, economic and accounting trends attached to them into the closed range of treaty income categories forces to analyze the basic elements of the tax treaty definitions of those categories of income, their mutual relationship, the role of the Commentaries and the effects derived from integration between the tax treaty requirements and the tax regime and qualifications of the income arising from the hybrid financial instrument. Despite the limited effects associated to the qualification of income arising from the hybrid financial instruments, the article further analyzes the effects derived from the interaction of the legal and qualification regimes of the income in the 'source' and the 'residence' contracting States, to verify what type of interaction and consequences derived and, according to those consequences, what type of measures can be applied to prevent undesired tax treaty results. In particular, the issue of the legitimate use of tax arbitrage schemes is considered and also the counteracting measures foreseen to prevent this usage and also its compatibility with tax treaty requirements.
Author :Félix Daniel Martínez Laguna Publisher :Kluwer Law International B.V. ISBN 13 :9403510846 Total Pages :685 pages Book Rating :4.4/5 (35 download)
Book Synopsis Hybrid Financial Instruments, Double Non-Taxation and Linking Rules by : Félix Daniel Martínez Laguna
Download or read book Hybrid Financial Instruments, Double Non-Taxation and Linking Rules written by Félix Daniel Martínez Laguna and published by Kluwer Law International B.V.. This book was released on 2019-06-12 with total page 685 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
