P. 1
LLM dissertation_taxation on hybrid securities

LLM dissertation_taxation on hybrid securities

Ratings: (0)|Views: 1,291 |Likes:
Published by z_xar1884

More info:

Published by: z_xar1884 on Apr 17, 2010
Copyright:Attribution Non-commercial

Availability:

Read on Scribd mobile: iPhone, iPad and Android.
download as PDF, TXT or read online from Scribd
See more
See less

07/23/2014

pdf

text

original

 
QUEEN MARY, UNIVERSITY OF LONDONLAW DEPARTMENT
LL.M in Taxation Law
DEBT AND EQUITY CLASSIFICATION OF HYBRID SECURITIES ANDTHE UK TAX TREATMENT ON HYBRID SECURITIES
Examination Number: LD227Supervisor: Dr. Christiana PanayiNumber of words: 13,475Date submitted: 18
th
August 2008
 
2
Contents
 Abbreviations and References4 Introduction5
Chapter 1 The use of hybrid securities and credit rating perspective8
What are hybrid securities?8The nature of equity and its replication in hybrids9Special feature: Payment in shares12The nature of debt obligation and its replication in hybrids13Why issue hybrids? An issuers perspective14Why invest in hybrids? An investors perspective15Why use hybrids? Taxation perspective15
Chapter 2 Domestic tax law classification and tax treaty classification18
Overview18Domestic tax law classification19First method: Integration19Second method: Bifurcation21Thin Capitalisation classification22Cross-border situation23Tax treaty classification24Dividend definition25Interest definition27Double taxation relief28
Chapter 3 UK tax law classification30
Overview30Tax treatment of interest paid32
 
3
Application of integration method: Reclassification of payments32Application of bifurcation method34UK Thin Capitalisation classification35Accounting classification35Consequences of classification under integration method36Consequences of classification under bifurcation method: Convertible bonds39Application of withholding tax 41
Conclusion43Bibliography45

Activity (23)

You've already reviewed this. Edit your review.
rboeckel liked this
1 thousand reads
1 hundred reads
sauravv7 liked this
sjoerd80 liked this
Ferdisha Snagg liked this
rishi.singh liked this
ABANISH1 liked this
ABANISH1 liked this
Nigel Kong liked this

You're Reading a Free Preview

Download
/*********** DO NOT ALTER ANYTHING BELOW THIS LINE ! ************/ var s_code=s.t();if(s_code)document.write(s_code)//-->