Hybrid Financial Instruments, Double Non-taxation and Linking Rules focuses on the analysis of double non-taxation stemming from hybrid financial instruments (HFIs) and the solution provided by the Organisation for Economic Co-operation and Development (OECD) and the European Union (EU) tackling double non-taxation related to cross-border HFIs. 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 OECD and the anti-avoidance initiatives of the EU. These complex rules have now become essential in international taxation.
